2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2023-003 Program: COVID-19 Aging Cluster Assistance Listing No.: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Aging Award No. and Year: Various Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control over Compliance and Instance of Non-Compliance Criteria: 2 CFR section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR section 200.332(a), Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as the 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 award. 2 CFR section 200.332(b), Requirements for Pass-Through Entities, states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations and the terms and conditions of the subaward for purpose of determining the appropriate subrecipient monitoring. Condition: We noted 6 instances out of 6 where the County did not include in the subrecipient agreement the subrecipient’s unique entity identifier and the subrecipient’s Federal Award identification Number (FAN) in accordance with 2 CFR 200.332(a) of the Uniform Guidance. In addition, we noted 6 instances out of 6 where the County did not perform a risk assessment on the program’s subrecipients for purposes of determining the appropriate subrecipient monitoring in accordance with 2 CFR 200.332(b) of the Uniform Guidance. Cause: The County did not ensure that the required award information was communicated to subrecipients. Additionally, the County did not document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect: The County did not identify the required elements of the subaward to the subrecipients at the time of subaward nor did the County document the evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 6 subrecipients out of 18 subrecipients were selected for testing. The condition noted above was identified during our procedures over the County’s subrecipient monitoring procedures. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County follow the implemented policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.332(a) and that the required evaluation of the subrecipient’s risk of noncompliance be documented in accordance with 2 CFR section 200.332(b). Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding 2023-001 – Subrecipient Monitoring (Aging Cluster) (Significant Deficiency) Assistance Listing Numbers Affected: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR 200.332(d) through (f)- Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). Pass-through entity monitoring of the subrecipient must also include the information at 2 CFR 200.332(d)(1) through (4). Additionally, per the grant agreement from the California Department of Aging, on-site program monitoring is required to be performed every two years. Condition: We noted Fresno-Madera Area Agency on Aging (the Agency) did not perform required monitoring activities of the subrecipients during the fiscal year. These are required elements of the subaward in accordance with 2 CFR 200.332(a) of the Uniform Grant Guidance. Cause: The Agency had internal personnel changes which caused this issue as there were not sufficient personnel resources to perform all required monitoring activities. Effect: There is an increased risk that subrecipients could not be in compliance or could have material questioned costs of noncompliance related to the program. Recommendation: We recommend that the Agency perform required monitoring activities over subrecipients in a timely manner in accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, the California Department of Aging, and the Agency’s own policies and procedures. Management’s Response: See Corrective Action Plan.
Finding Reference Number: 2023-005 NH Department of Justice NH Department of Health and Human Services NH Department of Environmental Services NH Department of Business and Economic Affairs COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Federal Award Numbers: SLFRP0145 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-008 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorization purposes, complies with the terms and conditions of the subaward 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities to support allowable activities under the federal program. During the year ended June 30, 2022, the State passed through $73,337,682 to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following breakdown of internal controls: A. As part of our testwork over subrecipient monitoring, we selected a sample of 49 items from the listing of subrecipients provided by the State that reconciled to the amount reported on the Schedule of Expenditures of Federal Awards. Of the 49 items selected for testwork, 6 items were contracts and were not subrecipient agreements. As such, we were unable to determine the completeness and accuracy of the subrecipient population. As a result of our audit, the State identified that this error resulted in the amount reported on the Schedule of Expenditures of Federal Awards as pass-through expenditures to be overstated by $7,261,684. The State has corrected the Schedule of Expenditures of Federal Awards so that the amount reported is accurate. B. The State communicates award information to subrecipients through the approved grant agreement. For 19 of the 43 remaining subrecipients selected for testwork, the State did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) was not communicated for 19 of the 43 remaining subrecipients selected for testwork. b. Identification of whether the award is R&D was not communicated for 17 of the remaining 43 subrecipients selected for testwork. C. As part of our testwork over during the award monitoring, it was identified that subrecipient monitoring activities include the review and approval of invoices submitted for reimbursement from the subrecipient. During our testwork over the invoice review we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, we were unable to obtain the invoices paid by the State to verify that they were reviewed and approved. While the invoices were not provided to us, we noted that other monitoring procedures were performed for 4 of the 6 subrecipients. b. For 10 of the remaining 43 subrecipients selected for testwork, while we were able to obtain the invoices paid by the State, we were unable to properly identify who the appropriate reviewer was for the invoice to ensure that the individual who approved the invoice had the appropriate knowledge and competency to perform the review process. As a result, we were unable to verify if the invoice was appropriately reviewed. While we were unable to verify this, we noted that other monitoring procedures were performed for 9 of the 10 subrecipients. D. As part of our testwork over during the award monitoring, for 9 of the 43 remaining subrecipients selected for testwork, no documentation was provided to support that during the award monitoring procedures had been performed during the audit period. As such, we could not verify that appropriate monitoring procedures were performed as outlined by the subrecipient’s risk assessment. E. As part of our testwork over the review of Uniform Guidance Reports, we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, the State provided the subrecipients Uniform Guidance report, however there was no evidence that the reports were reviewed to determine if a management decision letter needed to be issued. As part of our audit, we reviewed the 6 uniform guidance reports and did not identify any findings that would have required to be followed up on by the State. b. For 7 of the remaining 43 subrecipients selected for testwork, the subrecipient’s uniform guidance report was not provided. We reviewed the FAC to determine if a report was submitted during the audit period and identified that all 7 subrecipients had submitted a uniform guidance report. Of the 7 subrecipients, 1 report contained findings reported within Section III of the report. There was no evidence provided that the State had issued a management decision related to this subrecipient. Cause The cause of the condition found is primarily due to insufficient internal controls and procedures to ensure that award identification information is communicated, that appropriate during the award monitoring is performed based on the risk assessments and that all subrecipients are reviewed to determine if a uniform guidance audit was issued regardless of amount awarded to the subrecipient. Given the nature of this program, several Departments within the State entered into subrecipient grants resulting in a decentralized process. Not all Departments within the State are experienced with subrecipient relationships and may not have had developed policies to comply with subrecipient monitoring requirements. Finally, the State does not have sufficient internal controls in place to properly classify contracts and subrecipient relationships. Effect The effect of the condition found is that the State may not have properly monitored subrecipients in accordance with State policies and federal requirements. In addition, improper identification of contracts and subrecipients could lead to noncompliance with the State’s procurement policy or the proper monitoring of subrecipients. Questioned Costs None. Recommendation We recommend that the State review its existing internal controls, policies, and procedures to ensure that the State complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(d through (f), and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. Ensure that appropriate during the award monitoring is performed as outlined within the subrecipient’s risk assessment; and 3. All subrecipients are reviewed regardless of the amount awarded to determine if a uniform guidance report was issued and if a management decision letter should be issued. In addition, the State should continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring 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 other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring 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 other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
Finding Reference Number: 2023-017 NH Department of Health and Human Services Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) and COVID-19 Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) Federal Award Numbers: 1B08Ti084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $7,720,172 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. The Department provided the most recent risk assessment performed for each of the 7 subrecipients selected for testwork. Per review of the risk assessments provided, we identified the following: 1. For 5 of the subrecipients, the risk assessment indicated that the subrecipients expenditure detail should be examined monthly to ensure compliance with contract requirements and applicable laws and rules. We were unable to determine if this procedure had been performed as part of the Department’s subrecipient monitoring process. 2. For the remaining 2 subrecipients the recommended monitoring procedures was left blank on the risk assessment and as such we are unable to verify what type of monitoring procedures should have been performed. B. The Department’s during the award monitoring for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified that for 2 of 7 subrecipients selected for testwork, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department review its existing policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials Management partially concurs with the finding above. Rejoinder As it relates to Bullet A above, we were not able to obtain documentation to support that the suggested procedures outlined within the risk assessment was performed. As it relates to Bullet B above, for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement.
Finding Reference Number: 2023-017 NH Department of Health and Human Services Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) and COVID-19 Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) Federal Award Numbers: 1B08Ti084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $7,720,172 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. The Department provided the most recent risk assessment performed for each of the 7 subrecipients selected for testwork. Per review of the risk assessments provided, we identified the following: 1. For 5 of the subrecipients, the risk assessment indicated that the subrecipients expenditure detail should be examined monthly to ensure compliance with contract requirements and applicable laws and rules. We were unable to determine if this procedure had been performed as part of the Department’s subrecipient monitoring process. 2. For the remaining 2 subrecipients the recommended monitoring procedures was left blank on the risk assessment and as such we are unable to verify what type of monitoring procedures should have been performed. B. The Department’s during the award monitoring for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified that for 2 of 7 subrecipients selected for testwork, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department review its existing policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials Management partially concurs with the finding above. Rejoinder As it relates to Bullet A above, we were not able to obtain documentation to support that the suggested procedures outlined within the risk assessment was performed. As it relates to Bullet B above, for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement.
Finding Reference Number: 2023-023 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2023, $27,041,873 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 27 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: - Subrecipient unique entity identifier (not communicated for 19/27); - Federal Award Identification Number (FAIN) (not communicated for 27/27); - Identification of whether the award is R&D (not communicated for 27/27); and - Indirect cost rate for the federal award (including if the de minimis rate is charged) (not communicated for 27/27) B. The Department evaluated the subrecipient risk of noncompliance through a risk assessment for each of the 13 subrecipients selected for testwork. However, there was no formal risk assessment policy in place that indicated how frequently risk assessments should be performed. As a result, 5 subrecipients did not have risk assessments performed during the current year for purposes of determining the appropriate subrecipient monitoring response. These prior fiscal year(s) risk assessments were performed as of the following dates: September 2019, October and December 2021, May and June 2022. C. For each of the 13 subrecipients selected for testwork, the Department did not perform any during the award monitoring. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no UG report review policies and procedures in place. For the 13 subrecipients selected for testwork, 6 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 5 of 13 subrecipients, the subrecipient’s uniform guidance was not reviewed due to updated risk assessments not being performed in the current year (refer to item 2 above) • For 1 of 13 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report Cause The cause of the condition found was primarily due to the Department not performing their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-023 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2023, $27,041,873 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 27 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: - Subrecipient unique entity identifier (not communicated for 19/27); - Federal Award Identification Number (FAIN) (not communicated for 27/27); - Identification of whether the award is R&D (not communicated for 27/27); and - Indirect cost rate for the federal award (including if the de minimis rate is charged) (not communicated for 27/27) B. The Department evaluated the subrecipient risk of noncompliance through a risk assessment for each of the 13 subrecipients selected for testwork. However, there was no formal risk assessment policy in place that indicated how frequently risk assessments should be performed. As a result, 5 subrecipients did not have risk assessments performed during the current year for purposes of determining the appropriate subrecipient monitoring response. These prior fiscal year(s) risk assessments were performed as of the following dates: September 2019, October and December 2021, May and June 2022. C. For each of the 13 subrecipients selected for testwork, the Department did not perform any during the award monitoring. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no UG report review policies and procedures in place. For the 13 subrecipients selected for testwork, 6 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 5 of 13 subrecipients, the subrecipient’s uniform guidance was not reviewed due to updated risk assessments not being performed in the current year (refer to item 2 above) • For 1 of 13 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report Cause The cause of the condition found was primarily due to the Department not performing their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Finding Number: 2023-002 – Subrecipient Monitoring Evaluation of Finding: Material Weakness/Noncompliance Federal Program: Community Services Block Grant Federal Assistance No.: 93.569 Title: CSBG-CV Federal Grantor: U.S. Department of Health and Human Services Pass-Through Entity: State of California, Health and Human Services Agency Grant number: 20F-3684 Criteria or specified requirement: 2 CFR sections 200.332 requires that pass-through entities evaluate each subrecipients risk of noncompliance with federal awards and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with the conditions of the subaward; and that subaward performance goals are achieved, at the time of sub-award. Condition: The Authority has procedures in place to comply with certain subrecipient monitoring requirements, however, the procedures did not include all requirements under 2 CFR sections 200.332 until March of 2023. The Authority is required to evaluate risk, monitor the activities of the subrecipient and ensure accountability of subrecipients, prior to, and at the time of, sub-awards. The primary activity performed by the Authority prior to March 2023, was the review of reimbursement request details to ensure that the subrecipient’s expenditures were eligible under the federal program. From March 2023 through June 2023, the Authority was following a newly implemented subrecipient monitoring policy. Cause: The Authority did not have a subrecipient monitoring policy in place for at the time of sub-award until March 2023. Effect: The subrecipients were not sufficiently monitored as required under Uniform Guidance for the full fiscal year. Questioned Costs: None Context: The Authority’s policy did not include all of the required monitoring activities resulting in a systemic deficiency in subrecipient monitoring, until a new policy was implemented in March 2023. Recommendation: We recommend that the Authority continue following their newly established policy to include all subrecipient monitoring activities and consider including alternative procedures for onsite reviews when in person monitoring cannot take place. Additionally, we recommend this policy is reviewed on an annual basis for potential amendments, as a best practice. Management Response and Corrective Action: We are in agreement with the finding. These were discovered during the 2022 CSD desk audit and as a result, a revised subrecipient monitoring policies and procedures manual was drafted. In addition, the following actions were also taken: 1. The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures were updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment is conducted for each subrecipient. As stated in the finding, a new subrecipient monitoring policy was implemented in March 2023 and staff has following this policy since that time and will continue to do so.
Finding Number: 2023-002 – Subrecipient Monitoring Evaluation of Finding: Material Weakness/Noncompliance Federal Program: Community Services Block Grant Federal Assistance No.: 93.569 Title: CSBG-CV Federal Grantor: U.S. Department of Health and Human Services Pass-Through Entity: State of California, Health and Human Services Agency Grant number: 20F-3684 Criteria or specified requirement: 2 CFR sections 200.332 requires that pass-through entities evaluate each subrecipients risk of noncompliance with federal awards and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with the conditions of the subaward; and that subaward performance goals are achieved, at the time of sub-award. Condition: The Authority has procedures in place to comply with certain subrecipient monitoring requirements, however, the procedures did not include all requirements under 2 CFR sections 200.332 until March of 2023. The Authority is required to evaluate risk, monitor the activities of the subrecipient and ensure accountability of subrecipients, prior to, and at the time of, sub-awards. The primary activity performed by the Authority prior to March 2023, was the review of reimbursement request details to ensure that the subrecipient’s expenditures were eligible under the federal program. From March 2023 through June 2023, the Authority was following a newly implemented subrecipient monitoring policy. Cause: The Authority did not have a subrecipient monitoring policy in place for at the time of sub-award until March 2023. Effect: The subrecipients were not sufficiently monitored as required under Uniform Guidance for the full fiscal year. Questioned Costs: None Context: The Authority’s policy did not include all of the required monitoring activities resulting in a systemic deficiency in subrecipient monitoring, until a new policy was implemented in March 2023. Recommendation: We recommend that the Authority continue following their newly established policy to include all subrecipient monitoring activities and consider including alternative procedures for onsite reviews when in person monitoring cannot take place. Additionally, we recommend this policy is reviewed on an annual basis for potential amendments, as a best practice. Management Response and Corrective Action: We are in agreement with the finding. These were discovered during the 2022 CSD desk audit and as a result, a revised subrecipient monitoring policies and procedures manual was drafted. In addition, the following actions were also taken: 1. The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures were updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment is conducted for each subrecipient. As stated in the finding, a new subrecipient monitoring policy was implemented in March 2023 and staff has following this policy since that time and will continue to do so.
Finding Number: 2023-002 – Subrecipient Monitoring Evaluation of Finding: Material Weakness/Noncompliance Federal Program: Community Services Block Grant Federal Assistance No.: 93.569 Title: CSBG-CV Federal Grantor: U.S. Department of Health and Human Services Pass-Through Entity: State of California, Health and Human Services Agency Grant number: 20F-3684 Criteria or specified requirement: 2 CFR sections 200.332 requires that pass-through entities evaluate each subrecipients risk of noncompliance with federal awards and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes in compliance with the conditions of the subaward; and that subaward performance goals are achieved, at the time of sub-award. Condition: The Authority has procedures in place to comply with certain subrecipient monitoring requirements, however, the procedures did not include all requirements under 2 CFR sections 200.332 until March of 2023. The Authority is required to evaluate risk, monitor the activities of the subrecipient and ensure accountability of subrecipients, prior to, and at the time of, sub-awards. The primary activity performed by the Authority prior to March 2023, was the review of reimbursement request details to ensure that the subrecipient’s expenditures were eligible under the federal program. From March 2023 through June 2023, the Authority was following a newly implemented subrecipient monitoring policy. Cause: The Authority did not have a subrecipient monitoring policy in place for at the time of sub-award until March 2023. Effect: The subrecipients were not sufficiently monitored as required under Uniform Guidance for the full fiscal year. Questioned Costs: None Context: The Authority’s policy did not include all of the required monitoring activities resulting in a systemic deficiency in subrecipient monitoring, until a new policy was implemented in March 2023. Recommendation: We recommend that the Authority continue following their newly established policy to include all subrecipient monitoring activities and consider including alternative procedures for onsite reviews when in person monitoring cannot take place. Additionally, we recommend this policy is reviewed on an annual basis for potential amendments, as a best practice. Management Response and Corrective Action: We are in agreement with the finding. These were discovered during the 2022 CSD desk audit and as a result, a revised subrecipient monitoring policies and procedures manual was drafted. In addition, the following actions were also taken: 1. The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures were updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment is conducted for each subrecipient. As stated in the finding, a new subrecipient monitoring policy was implemented in March 2023 and staff has following this policy since that time and will continue to do so.
Finding 2023-206 The Department did not fully disclose required information to subrecipients, document subrecipient risk assessments, or ensure subrecipient audits were received for the Coronavirus State and Local Fiscal Recovery Fund. Type of Finding: Significant Deficiency, Noncompliance Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing Number: 21.027 Federal Award Number: SLFRP0142 Program Year: March 3, 2021 - December 31, 2024 Federal Agency: Department of Treasury Compliance Requirement: Subrecipient Monitoring Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR) Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200.303) states that nonfederal entities must establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations and the terms and conditions of the federal award. The requirements for pass-through entities are in 2 CFR 200.332, which states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and include the following information at the time of the subaward or if information changes. Required information includes: • Federal Award Identification 1. Subrecipient’s name (which must match the name associated with its unique entity identifier); 2. Subrecipient’s unique entity identifier; 3. Federal Award Identification Number (FAIN); 4. Federal award date of award to the recipient by the federal agency 5. Subaward period of performance start and end date; 6. Subaward budget period start and end date; 7. Amount of federal funds obligated by this action by the pass-through entity to the subrecipient; 8. Total amount of federal funds obligated to the subrecipient by the pass-through entity to the subrecipient; 9. Total amount of the federal award committed to the subrecipient by the pass-through entity; 10. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); 11. Name of awarding agency, pass-though entity, and contact information for awarding official of the pass-through entity; 12. Assistance Listings (AL) number and title; 13. Identification of whether the award is research and development (R&D); and 14. Indirect cost rate for the federal award • 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. • 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, included identification of any required financial and performance reports. Pass-through entities must also: • Evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. • Consider imposing specific subaward conditions upon a subrecipient, if appropriate. • 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 subawards, and that subaward performance goals are achieved. • Verify that every subrecipient is audited as required by 2 CFR 200, Subpart F, and follow up on the results of those audits. Condition: The Department received funds for the Coronavirus State and Local Fiscal Recovery Fund (SLFRF, AL number 21.027) from the U.S. Department of Treasury through the Idaho Division of Financial Management. The Department passed through $18,941,327 from the SLFRF to 74 subrecipients. We selected a sample of 8 subrecipients to test compliance with these requirements. We found the Department complied with some, but not all, of the pass-through entity requirements. The Department did not provide the following required information in all 8 of the items tested: • Federal Award Identification Number (FAIN) • Federal award date of award to the recipient by the federal agency • Subaward period of performance start and end dates • Total amount of federal award committed to the subrecipient • Identification of whether the award is for (R&D) • Indirect cost rate for the federal award The Department did not provide the AL number to 3 of the 8 subrecipients tested and provided an incorrect AL number to 4 of the 8 subrecipients tested. The Department implemented the grant in the Waste Management and Remediation Division and the Grants and Loans Bureau. Single Audit reports are required to be submitted to pass-through entities no later than 9 months after the subrecipient’s fiscal year end or within 60 days of the issuance of the report. The Department passed funds through to subrecipients beginning in fiscal year 2023; therefore, no subrecipient Single Audit reports would be due during our audit period. However, we reviewed procedures the Department implemented to ensure that these audits would be collected when due. We found that the Grants and Loans Bureau had procedures in place that would be effective in collecting and evaluating the subrecipient reports; however, the Waste Management and Remediation Division did not have effective procedures to collect the reports. Cause: The Department used a basic template in creating an award letter and grant agreement. The template did not include all the required information. The FAIN was not communicated to the Department by the Division of Financial Management. The Department was also unaware that the FAIN and AL number were different. The period of performance was not included because the Department provided the budget period for the project and was concerned that subrecipients would be confused about the spending period for their grants. The Department did not identify whether the grant was for R&D because they felt it was sufficiently communicated that the funds were for planning, construction, or waste management projects and not for R&D. The indirect rate was not included because the Department communicated that the funds were for construction costs only, which does not include indirect costs. The Department did not have a formal documented risk assessment because they believed that this was sufficiently done during the application process and during the actual grant award period. However, these procedures are informal, and no documentation is retained that specifically identifies risks of noncompliance with federal grant rules for the purpose of determining monitoring procedures. The Waste Management and Remediation Division did not have procedures to collect subrecipient Single Audit reports because they believed that the fiscal operations division would perform that function. Our discussions with the fiscal operations found that there was a position with the assigned duties to collect subrecipient Single Audits, but that position was vacant during fiscal year 2023, and the Department had difficulty filling the position. Effect: Subrecipient monitoring is a critical requirement as part of accepting federal funds and ensuring that those funds are spent in compliance with allowable costs and other guidelines provided by the grantor. Subrecipients need the required grant information to properly implement, manage, and report the federal award. Without this information, subrecipients have an increased risk of noncompliance with the federal award requirements. Assessing the risk of subrecipient noncompliance enables a pass-through entity to determine the proper level of monitoring procedures. Without completing the risk assessment process, a pass-thought entity may increase the risk that appropriate monitoring procedures will not be performed at a sufficient level to detect noncompliance or that a subrecipient will not comply with the grant terms. There were no subrecipient Single Audit reports due during our audit period; however, a well-designed procedure for collecting these reports is an important pass-through entity responsibility. Subrecipient audit reports may identify internal control issues and noncompliance with federal award requirements. Reviewing these reports and ensuring that potential issues are addressed decreases the overall risk of noncompliance with the federal award requirements. Recommendation: We recommend that the Department design and implement appropriate procedures to ensure that all required information is communicated to subrecipients at the time of the award, subrecipient risk assessments are properly completed and documented, and subrecipient audits are completed and reviewed in accordance with federal grant regulations. Management’s View: The department agrees with the lack of certain required subrecipient information datapoints for the CSLFRF projects. Corrective Action: The department had an imperfect implementation of the initial subawards for CSLFRF documentation for subrecipients. Our general practice includes providing the identified federal award identification datapoints; however, this was not the case with the initial CSLFRF subrecipients. As an example, the period of performance was truncated to ensure that we were able to meet the aggressive timeline outlined in the American Rescue Plan Act; we will include both the true period of performance as set forth in the grant and the budgetary period in which the subrecipient will need to complete their work. Carrie Champlin, Contracts Manager, and Rob Sepich, Chief Financial Officer will implement these changes by April 15, 2024. The department had processes for evaluating the risk of subrecipients, however it could be improved and made clearer for auditors and we will implement a process used by other agencies to memorialize the risk factors outside of email in a clear and concise manner. Additionally, the department is currently implementing a new software system, Amplifund, to aid in registering subrecipients, monitoring them, and closing out subawards. This system will include all of the relevant information necessary for both the subrecipient and the department in one location and will provide consistency across the department. Amplifund implementation is currently underway and will be used department- wide by August 2024. Doug McRoberts, Grants Manager, Jeri Ann Fogg, Accounting Manager, Carrie Champlin, Contracts Manager are working on the integration of Amplifund. Auditor’s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2023-213 The Department erroneously determined that two recipients of Temporary Assistance for Needy Families (TANF) funding were contractors instead of subrecipients resulting in noncompliance with the subrecipient monitoring requirements. Type of Finding: Material Weakness, Material Noncompliance Assistance Listing Title: Temporary Assistance for Needy Families Assistance Listing Number: 93.558 Federal Award Number: 2201IDTANF; 2301IDTANF Program Year: October 1, 2021 – September 30, 2022; October 1, 2022 – September 30, 2023 Federal Agency: Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include items such as approvals, authorizations, verifications, reconciliations, and segregation of duties. The Uniform Guidance included in 2 CFR 200.331 describes the Department’s, a pass-through entity, responsibility for completing subrecipient and contractor determinations. The Uniform Guidance included in 2 CFR 200.332 (a) states that 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. Also, if any of these data elements change, include the changes in subsequent subaward modification. (1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal award date (see the definition of federal award date in 2 CFR 200.1 of this part) of award to the recipient by the federal agency; (v) Subaward period of performance start and end date; (vi) Subaward budget period start and end date; (vii) Amount of federal funds obligated by this action by the pass-through entity to the subrecipient; (viii) Total amount of federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total amount of the federal award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required 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 and title; the pass-through entity must identify the dollar amount made available under each federal award and the Assistance Listings number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the federal award, including if the de minimis rate is charged per 2 CFR 200.414. If any of the required information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. The Uniform Guidance included 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 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 (for example, if the subrecipient also receives federal awards directly from a federal awarding agency). Condition: The Department erroneously determined that two recipients of TANF funding were contractors instead of subrecipients. A contractor provides services or goods while a subrecipient has additional responsibilities related to the grant administration. Because of that, there are additional requirements when passing through funds to a subrecipient, rather than making a payment to a vendor. We tested one of the two subrecipients for compliance purposes. The award was not identified to the subrecipient as a subaward and did not include all the necessary information at the time of the subaward. In addition, the subrecipient's risk of noncompliance was not evaluated. Cause: During our analysis of the subrecipient monitoring compliance requirement, we learned that the Department’s program staff determined that some of the recipients of TANF funding were contractors. However, the Department’s financial staff reported the expenditures as payments to subrecipients on the SEFA. After investigation, we found that the expenditures were made to subrecipients, not contractors. Effect: The Department is exposed to increased risk of noncompliance related to subrecipients and improper payments in the TANF program. The Department provided a total amount of $1.4 million to subrecipients during fiscal year 2023. Recommendation: We recommend that the Department implement proper training of personnel involved in subrecipient and contractor determinations. In addition, we recommend that the Department design and implement effective internal control procedures to ensure all required information is provided to subrecipients at the time of subawards and that the Department complete the required evaluations of each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Management’s View: The Department agrees with the finding. Corrective Action: The Department has revised our training of personnel involved in subrecipient and contractor determinations. These contract managers and monitors completed grant training on March 12th-13th, 2024 which included sections about subrecipient and contractor determinations, risk assessment and documentation. All newly hired employees will be trained beginning April 2024 with an on-line module. For the impacted vendor, an updated Risk Assessment was completed and submitted to LSO. Additionally, the Department has started the work to effectively change the designation of the vendor and ensure all required information is provided to this subrecipient. This process will be completed by April 30th, 2024. The Department will develop internal control procedures to ensure all required information is provided to the subrecipients at the time of the subawards. These updated internal control procedures will be completed by June 30th, 2024. Auditor’s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2023-221 The Department did not review subrecipient application information for the Coronavirus State and Local Fiscal Recovery Funds at a sufficient level to identify missing information. Related to Prior Finding: 2022-210 Type of Finding: Significant Deficiency, Noncompliance Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number: 20-1982-0-1-806 Program Year: March 3, 2021 – December 31, 2024 Federal Agency: Department of Treasury Compliance Requirement: Subrecipient Monitoring Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include items such as approvals, authorizations, verifications, reconciliations, and segregation of duties. The Uniform Guidance included in 2 CFR 200.332 describes the pass-through entities’ responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations. The Uniform Guidance included in 2 CFR 200.332(a)(1)(iii) states that pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal Award Identification Number (FAIN) at the time of subaward. Condition: The Department used COVID State and Local Fiscal Recovery funds to respond to the public health and negative economic impacts resulting from the COVID-19 pandemic. The Division of Public Health and the Idaho Council on Domestic Violence and Victim Assistance were responsible for distributing these funds and created a process for their prospective recipients to apply and receive funding. During testing, we noted 2 applications out of our sample of 8 (25 percent) that did not include FAINs in application documentation, as required. Cause: The Department had review procedures in place; however, the reviews of subrecipient application documentation were not completed at a level sufficient to identify missing FAINs. Effect: The Department is exposed to increased risk of improper payments and noncompliance with federal requirements when applications do not meet all requirements for receiving funding. Recommendation: We recommend that the Department design and implement effective internal control procedures to ensure subrecipient applications are completed accurately and in compliance with federal requirements. Management’s View: The Department agrees with the finding. Corrective Action: The Division of Public Health and Idaho Council on Domestic Violence and Victim Assistance (ICDVVA) will take steps to ensure new staff receive training related to awarding grants, to include components on appropriate internal controls, identifying required grant elements, detailing the grant process, and outlining record retention requirements. All current employees have been trained as of March 2024. All newly hired employees will be trained beginning April 2024. Auditor’s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
FINDING 2023-222 Supporting documentation to demonstrate the completion of subrecipient risk assessments for the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program was not available for review. Type of Finding: Significant Deficiency, Noncompliance Assistance Listing Title: Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Assistance Listing Number: 93.391 Federal Award Number: 1 NH75OT000105-01-00; 6 NH75OT000105-01-00 Program Year: June 1, 2021 – May 31, 2024 Federal Agency: Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Questioned Costs: None Criteria: The U.S. Code of Federal Regulations (CFR), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) included in 2 CFR 200.303 requires that a nonfederal entity receiving federal awards establish and maintain internal controls that provide reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions in the federal award. The Internal Control Integrated Framework published by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) identifies control activities that help ensure management directives are carried out and risks are mitigated. These activities include items such as approvals, authorizations, verifications, reconciliations, and segregation of duties. The Uniform Guidance included in 2 CFR 200.332(b) states that all pass-through entities must evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: The Department was unable to provide a subrecipient risk assessment for 1 out of 8 (or 12.5 percent) subrecipients we reviewed. The Department was compliant with all other aspects of the subrecipient monitoring compliance requirements for that subrecipient. Cause: During the time in which the missing documentation was supposed to be created, the Department’s program staff were in the process of being hired and trained. Responsibilities were also being transitioned to the newly onboarded staff from the other program staff that assisted in the implementation of the grant. Effect: The Department is exposed to increased risk of noncompliance related to subrecipients and improper payments in the Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises program. Recommendation: We recommend that the Department strengthen internal controls to ensure required risk assessments are completed and supporting documentation is retained. Management’s View: The Department agrees with the finding. Corrective Action: The division will ensure new staff receive training related to awarding grants, to include components on appropriate internal controls, identifying required grant elements, detailing the grant process, and outlining record retention requirements. All current employees have been trained as of March 2024. All newly hired employees will be trained beginning April 2024. Auditor’s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.