Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing #21.027 - Award # 5070101; Passed through the Texas Office of the Governor- Criminal Justice Division. Criteria: 2 CFR section 200.332 requires a pass-through entity to ensure that every subaward is clearly identified to the subrecipient as a subaward and include the information described in 2 CFR section 200.332 (b)(1). A pass-through entity must provide the best available information when some of the information is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Condition /Context: Subrecipients did not receive notice or an updated subaward agreement when the grant funding source changed from state to federal funding. Therefore, not all required subaward information under the Uniform Guidance was provided, specifically: - Federal Award Identification Number (FAIN) - Federal award date of award to the recipient by the federal agency - Total amount of federal funds obligated to the subrecipient by the pass-through entity, including the current financial obligation - Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity - Assistance listing number and title Questioned Costs: None Effect: Texas CASA, Inc. was not in compliance with the Uniform Guidance requirements as it relates to subrecipient award agreement elements. Cause: During the fiscal year, the granting agency awarded additional funds to Texas CASA, Inc., which changed the funding source from state to federal funds. Texas CASA, Inc. did not have a process in place to communicate the changes in funding sources to the subrecipients. Recommendations: Texas CASA, Inc. should prepare and implement procedures to timely communicate any necessary revisions or changes to subawards to the subrecipients. Views of Responsible Officials and Planned Corrective Actions: See Schedule of Corrective Action Plan
Reference Number 2024-004 Subaward Agreements Federal Awards: GEAR UP (ALN 84.334A) Criteria and Condition: A pass-through entity must clearly identify to the subrecipient; (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(b)(1); (2) 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 award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. We noted a formal subaward agreement outlining all the required information is not prepared and executed by the Center (pass-through entity) and its subrecipients. Amended guidance was communicated to the Center as 34 CFR 75.127 through 75.129 was amended on August 29, 2024. Under this new guidance, an agreement that details the activities that each member of the group plans to perform, and binds each member of the group to every statement and assurance made by the application will be required on an ongoing basis. The Center intends to comply with this requirement on an ongoing basis. Cause and Effect: The Center provides separate documents to its subrecipients such as the District/Campus Commitment Form that outlines some of the applicable compliance requirements and a Program Budget Award Worksheet. A formal subaward agreement executed by both parties containing all the information required by 200.332(b)(1) is not in place. This results in noncompliance with subrecipient monitoring requirements. Repeat Finding from Prior Year(s): N/A Questioned Costs: $0 Recommendation: As 34 CFR 75.127 through 75.129 was amended on August 29, 2024, we recommend management implement this guidance and maintain formal agreements between the Center and the subrecipients/partners in the program. Views of Responsible Officials: See management’s corrective action plan.
Reference Number 2024-004 Subaward Agreements Federal Awards: GEAR UP (ALN 84.334A) Criteria and Condition: A pass-through entity must clearly identify to the subrecipient; (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(b)(1); (2) 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 award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. We noted a formal subaward agreement outlining all the required information is not prepared and executed by the Center (pass-through entity) and its subrecipients. Amended guidance was communicated to the Center as 34 CFR 75.127 through 75.129 was amended on August 29, 2024. Under this new guidance, an agreement that details the activities that each member of the group plans to perform, and binds each member of the group to every statement and assurance made by the application will be required on an ongoing basis. The Center intends to comply with this requirement on an ongoing basis. Cause and Effect: The Center provides separate documents to its subrecipients such as the District/Campus Commitment Form that outlines some of the applicable compliance requirements and a Program Budget Award Worksheet. A formal subaward agreement executed by both parties containing all the information required by 200.332(b)(1) is not in place. This results in noncompliance with subrecipient monitoring requirements. Repeat Finding from Prior Year(s): N/A Questioned Costs: $0 Recommendation: As 34 CFR 75.127 through 75.129 was amended on August 29, 2024, we recommend management implement this guidance and maintain formal agreements between the Center and the subrecipients/partners in the program. Views of Responsible Officials: See management’s corrective action plan.
Reference Number 2024-004 Subaward Agreements Federal Awards: GEAR UP (ALN 84.334A) Criteria and Condition: A pass-through entity must clearly identify to the subrecipient; (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(b)(1); (2) 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 award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. We noted a formal subaward agreement outlining all the required information is not prepared and executed by the Center (pass-through entity) and its subrecipients. Amended guidance was communicated to the Center as 34 CFR 75.127 through 75.129 was amended on August 29, 2024. Under this new guidance, an agreement that details the activities that each member of the group plans to perform, and binds each member of the group to every statement and assurance made by the application will be required on an ongoing basis. The Center intends to comply with this requirement on an ongoing basis. Cause and Effect: The Center provides separate documents to its subrecipients such as the District/Campus Commitment Form that outlines some of the applicable compliance requirements and a Program Budget Award Worksheet. A formal subaward agreement executed by both parties containing all the information required by 200.332(b)(1) is not in place. This results in noncompliance with subrecipient monitoring requirements. Repeat Finding from Prior Year(s): N/A Questioned Costs: $0 Recommendation: As 34 CFR 75.127 through 75.129 was amended on August 29, 2024, we recommend management implement this guidance and maintain formal agreements between the Center and the subrecipients/partners in the program. Views of Responsible Officials: See management’s corrective action plan.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) Social Services Block Grant (SSBG) ALN: 93.558 93.667 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2401TXTANF, 2401TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2023 – September 30, 2024 SSBG 2401TXSOSR October 1, 2023 – September 30, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information at the time of the subaward and if any of these data elements change, include the changes in the subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes the subrecipient’s unique entity identifier (UEI). Condition: Audit procedures included a review of subaward agreements for required information. We noted the following instances of noncompliance: Temporary Assistance for Needy Families – The UEI was not included in eight of the eight agreements selected for testing. The start and end dates for the agreements were September 1, 2020 – August 31, 2024. Social Services Block Grant –The UEI was not included in one of the 19 agreements selected for testing. The start and end dates for the agreement was January 1, 2021 – August 31, 2024. Questioned costs: None. Context: See “Condition.” Cause: The current contract review process to ensure all required elements are included per 2 CFR 200 §200.332 prior to execution is not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: 2023-011 Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) Social Services Block Grant (SSBG) ALN: 93.558 93.667 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2401TXTANF, 2401TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2023 – September 30, 2024 SSBG 2401TXSOSR October 1, 2023 – September 30, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information at the time of the subaward and if any of these data elements change, include the changes in the subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes the subrecipient’s unique entity identifier (UEI). Condition: Audit procedures included a review of subaward agreements for required information. We noted the following instances of noncompliance: Temporary Assistance for Needy Families – The UEI was not included in eight of the eight agreements selected for testing. The start and end dates for the agreements were September 1, 2020 – August 31, 2024. Social Services Block Grant –The UEI was not included in one of the 19 agreements selected for testing. The start and end dates for the agreement was January 1, 2021 – August 31, 2024. Questioned costs: None. Context: See “Condition.” Cause: The current contract review process to ensure all required elements are included per 2 CFR 200 §200.332 prior to execution is not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: 2023-011 Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Title: Temporary Assistance for Needy Families (TANF) Social Services Block Grant (SSBG) ALN: 93.558 93.667 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: TANF 2301TXTANF, 2301TXTAN3, 2401TXTANF, 2401TXTAN3 October 1, 2022 – September 30, 2023 and October 1, 2023 – September 30, 2024 SSBG 2401TXSOSR October 1, 2023 – September 30, 2025 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR 200.303(a), Health and Human Services Commission (HHSC) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information at the time of the subaward and if any of these data elements change, include the changes in the subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes the subrecipient’s unique entity identifier (UEI). Condition: Audit procedures included a review of subaward agreements for required information. We noted the following instances of noncompliance: Temporary Assistance for Needy Families – The UEI was not included in eight of the eight agreements selected for testing. The start and end dates for the agreements were September 1, 2020 – August 31, 2024. Social Services Block Grant –The UEI was not included in one of the 19 agreements selected for testing. The start and end dates for the agreement was January 1, 2021 – August 31, 2024. Questioned costs: None. Context: See “Condition.” Cause: The current contract review process to ensure all required elements are included per 2 CFR 200 §200.332 prior to execution is not at the correct precision level. Effect: Providing incomplete information to subrecipients may result in inaccurate reporting by the subrecipients and ultimately by HHSC. Repeat Finding: 2023-011 Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements by 2 CFR §200.332. Views of responsible officials: HHSC concurs with the finding.
Subrecipient Monitoring Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Home Investment Partnerships Program ALN: 14.239 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: M18-SG480100, M19-SP480100, M20-SG480100 September 12, 2018 – September 1, 2026, and July 12, 2019 – September 1, 2027, August 13, 2020 – September 1, 2028 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), the Texas Department of Housing and Community Affairs (TDHCA) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR sections 200.332 (c), TDHCA must evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, TDHCA should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have 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 any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). Condition: TDHCA maintains a Master Compliance Subrecipient Monitoring (CMSM) Planning Summary (MPS) to track all active subrecipient contracts that have expenditures in the planning phase to evaluate each subrecipient's fraud risk and risk of noncompliance with the subaward to determine the appropriate subrecipient monitoring to be performed. During our testing, we noted three subrecipient contracts with expenditures during the fiscal year were not included on the MPS for evaluation of fraud risk and risk of noncompliance. Accordingly, no determination was made for the appropriate subrecipient monitoring to be performed for these subrecipients. Questioned costs: None. Context: See “Condition.” Cause: The preparation of the MPS is a manual process wherein a senior analyst identifies the active contracts that have expenditures in the planning phase. The subrecipients were inadvertently omitted due to oversight. Effect: Failure to complete proper monitoring over subrecipients may lead to noncompliance with grant terms and conditions. Repeat Finding: No Recommendation: We recommend TDHCA establish internal controls that require a review to be completed over the completeness and accuracy of the MPS by an individual other than the preparer. Views of responsible officials: Compliance Subrecipient Monitoring (CMSM) has historically utilized the Department’s Housing Contract system to populate its risk population. “Active” contracts with expenditures are selected for risk consideration while “Expired”, “Closed” or unexpended contracts are excluded to promote internal efficiency in the monitoring process. During interviews with the auditor and the Department’s HOME staff, it was identified that there are circumstances where “Expired” or “Closed” contracts may demonstrate expenditure activity and inadvertently exclude contracts that could be included for risk consideration. Of note, this system generated discrepancy has not contributed to a material variance in contracts considered for risk assessment.
Subrecipient Monitoring Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: Home Investment Partnerships Program ALN: 14.239 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: M18-SG480100, M19-SP480100, M20-SG480100 September 12, 2018 – September 1, 2026, and July 12, 2019 – September 1, 2027, August 13, 2020 – September 1, 2028 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), the Texas Department of Housing and Community Affairs (TDHCA) must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR sections 200.332 (c), TDHCA must evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, TDHCA should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have 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 any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). Condition: TDHCA maintains a Master Compliance Subrecipient Monitoring (CMSM) Planning Summary (MPS) to track all active subrecipient contracts that have expenditures in the planning phase to evaluate each subrecipient's fraud risk and risk of noncompliance with the subaward to determine the appropriate subrecipient monitoring to be performed. During our testing, we noted three subrecipient contracts with expenditures during the fiscal year were not included on the MPS for evaluation of fraud risk and risk of noncompliance. Accordingly, no determination was made for the appropriate subrecipient monitoring to be performed for these subrecipients. Questioned costs: None. Context: See “Condition.” Cause: The preparation of the MPS is a manual process wherein a senior analyst identifies the active contracts that have expenditures in the planning phase. The subrecipients were inadvertently omitted due to oversight. Effect: Failure to complete proper monitoring over subrecipients may lead to noncompliance with grant terms and conditions. Repeat Finding: No Recommendation: We recommend TDHCA establish internal controls that require a review to be completed over the completeness and accuracy of the MPS by an individual other than the preparer. Views of responsible officials: Compliance Subrecipient Monitoring (CMSM) has historically utilized the Department’s Housing Contract system to populate its risk population. “Active” contracts with expenditures are selected for risk consideration while “Expired”, “Closed” or unexpended contracts are excluded to promote internal efficiency in the monitoring process. During interviews with the auditor and the Department’s HOME staff, it was identified that there are circumstances where “Expired” or “Closed” contracts may demonstrate expenditure activity and inadvertently exclude contracts that could be included for risk consideration. Of note, this system generated discrepancy has not contributed to a material variance in contracts considered for risk assessment.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Reporting – FFATA Subawards Federal Agency: U.S. Department of Labor Federal Program Title: Workforce Innovation and Opportunity Act Cluster ALN: 17.258, 17.259, 17.278 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Number and Period: 23A55AY000040–01–00 April 1, 2023 – June 30, 2026 Statistically Valid Sample: No, and not intended to be a statistically valid sample Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Criteria or specific requirement: Per 2 CFR section 200.303(a), Texas Workforce (TWC) must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that TWC is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109- 282), as amended by Section 6202 of Public Law 110-252, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Condition: As the prime recipient of grant funding, TWC is responsible for reporting first-tier subawards of $30,000 or more in FSRS. Audit procedures included testing 59 subawards made during the fiscal year for FFATA requirements, including subawards made by Texas Education Agency (TEA) using state pass through funds from TWC. TWC passed through $3,000,000 of federal grant funds to TEA who in turn made 33 subawards totaling $2,911,755. Based on Part 3 of the 2024 compliance supplement, transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship. Accordingly, subawards made by TEA should be reported in FSRS by TWC as the prime recipient. The following compliance exceptions were identified: See chart or table in the Schedule of Findings and Questioned Costs. Questioned costs: None Context: See “Condition.” Cause: TWC considered the funds passed through to TEA as a subaward and reported these amounts in FSRS. However, as TEA is an agency of the State of Texas, it does not meet the definition of a subrecipient. Effect: Failure to submit FFATA subawards timely may lead to noncompliance with federal requirements. Repeat Finding: No Recommendation: We recommend that, as the prime recipient, TWC coordinate with state pass through entities to obtain the information needed for FFATA reporting in order to be compliant with FFATA requirements. Views of responsible officials: In this situation, TWC disagrees with the applicability of the following statement “Transfers of federal awards to another component of the same auditee under 2 CFR Part 200, Subpart F, do not constitute a subrecipient or contractor relationship” from the Fiscal Year 2024 2 CFR Part 200, Appendix XI Compliance Supplement. According to 2 CFR Part 170, TWC is required to report first-tier subawards. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) which designates TEA as a subrecipient of TWC making TEA a first_x0002_tier grantee of TWC. Neither TWC nor TEA considers this funding a “transfer.” The definition of a pass-through entity according to 2 CFR Part 200, means a recipient or subrecipient that provides a subaward to a subrecipient (including lower tier subrecipients) to carry out a federal program. In the case of TWC and TEA, there is an Interagency Agreement Contract (IAC) that establishes a relationship that would not be considered a transfer but a first tier subaward. The IAC establishes TWC as a pass-through entity and TEA as a subrecipient per the definitions of these terms in 2 CFR 200.1. Under the requirements for pass-through entities at 2 CFR 200.332, TWC is responsible for monitoring TEA performance under this subaward which may include enforcement under 2 CFR 200.339 and the recovery of costs associated with subrecipient noncompliance. This contractual consideration and possibility of repayment supports that this relationship is one of pass-through and subrecipient, and not a transfer of a federal award to another component of an auditee. As such, subawards made by TEA are in fact second tier subawards for TWC and TWC has no obligation to report them as established in Appendix A 2 CFR Part 170. The Federal Funding Accountability and Transparency Act of 2006 (FFATA) was passed in the vein of openness and transparency to the public as it relates to Federal spending. Reporting on first-tier subawards took effect October 1, 2010. (See OMB Memorandum for Senior Accountable Officials, “Open Government Directive–Federal Spending Transparency and Subaward and Compensation Data Reporting,” August 27, 2010.) FFATA, § 2—Full Disclosure of Entities Receiving Federal Funding, directed the Office of Management and Budget to “ensure the existence and operation of a single searchable website, accessible by the public at no cost to access, that includes for each Federal award—(A) the name of the entity receiving the award” and other specified information. (See Public Law 109-282, §2(b).) That website is USASpending.gov. On that website, a search by “recipient” does not have an option to search for “State of Texas.” Rather, the search options individually list the Texas Workforce Commission and other Texas state agencies as separate recipients. When TWC makes an interagency pass-through contract to another state agency, TWC has always treated that other state agency as first-tier subrecipient for FFATA reporting purposes. That decision was based on guidance and interpretation of information available when the FFATA subaward reporting requirements took effect in 2010. TWC has continued in that manner with no audit finding on that approach until now. If TWC adheres to the recommendation made by this finding, the public will no longer have access to the interagency contract amounts through USASpending.gov. The USASpending.gov data presented to the public will instead indicate that the subrecipients of another state agency received subawards directly from TWC, which is inaccurate, will make the USASpending.gov data of the other state agency incomplete, and will cause the USASpending.gov data to be inconsistent with both state agencies’ presentation of those subawards in their respective systems and financial statements. In effect, the USASpending.gov data will represent the subawards of the other state agency as TWC’s subrecipients, while TWC’s systems and financial statements will have no record of those subawards beyond FFATA reporting. Similarly, the other state agency’s systems and financial statements will reflect those subawards as its own, but with no related reflection of that relationship in USASpending.gov. If the public were to submit an open records request about the subawards, the State’s response would be delayed by one state agency collecting data from the other, and inconsistent with the public’s expectation as to which state agency issued and managed those subawards. Those effects seem inconsistent with FFATA’s openness and transparency goals.
Program: Assistance Listing Number 59.059 – Congressional Earmarks Initiative Awarding Agency – U.S. Small Business Association Grant Number – SBAHQ23I0008 Federal Award Year – 2024 Questioned Cost: None. Criteria: Per 2 CFR 200.332, Central Michigan University Research Corporation is required to perform risk assessment and monitoring procedures for subrecipients of federal grants. This includes procedures such as evaluating the subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, review of financial and performance reports, and follow up of the subrecipient’s correction of previous Single Audit findings. Condition: The Organization lacked documentation that sufficient subrecipient risk assessment and monitoring procedures were performed as required by Uniform Guidance. An assumption was made that because the subrecipient was to receive funding as part of a federal mandate that the Organization’s only responsibility was to pass through the funding. Cause / Effect: Management does not have the proper policies and procedures in place to ensure that the required subrecipient procedures are being performed, causing noncompliance. Recommendation: We recommend that management reviews the required procedures for pass-through entities as listed in 2 CFR 200.332 and implements the procedures accordingly. This should include documented risk assessment and monitoring procedures for all subrecipient of federal awards. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See attached corrective action plan from management.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
2024 – 002: Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis response Assistance Listing Number: 93.354 Federal Award Identification Number: NU90TP922168, NU90TP921992 Pass-Through Agency: South Carolina Department of Health and Environmental Control Pass-Through Numbers: PH-2-533, CY-19-018 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Internal Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Compliance - Per 2 CFR section 200.332(a), the subaward is to clearly identify to the subrecipient required information, including identification of whether the award is R&D. Condition: The University incorrectly documented the subaward as a Research and Development grant to the subrecipient. Questioned costs: None Context: This condition occurred for 5 out of 5 subawards selected for testing. Cause: Attachment 2 of the Federal Awards Terms and Conditions template of the FDP Cost Reimbursement Subaward includes a field that is pre-selected and defaults to the R&D selection, requiring the field to be unchecked for the subawards that are not classified as R&D. Effect: The subrecipient may not be aware of certain award information in order to comply with federal statutes, regulations, and the terms and conditions of the award and properly classify its schedule of expenditures of federal awards. Repeat Finding: No Recommendation: We recommend the University strengthen its internal controls to ensure that subawards report the correct information. Views of responsible officials: Management acknowledges the finding.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
2024-003 Subrecipient Monitoring Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: Subrecipients were not monitored timely enough to perform the necessary evaluation on subrecipient activities or to report expenditures on the schedule of expenditures of federal awards in the appropriate fiscal year. Cause: UAS did not receive invoices for certain subrecipients until after year-end close and for amounts covering an entire fiscal year and no amounts were accrued. Effect: Activities of the subrecipient could not be reviewed timely to ensure authorized use or for allowability with grant terms and conditions. Subrecipient expenditures on the schedule of expenditures of federal awards were understated by $344,948. Questioned Costs: The conditions did not result in questioned costs greater than $25,000. Context: Although subrecipient invoices were submitted after year-end close, UAS grant personnel reviewed expenses submitted for allowability and did not identify any disallowed costs. Repeat Finding: No. Recommendation: Establish a timeline for subrecipients to provide required reports to UAS in order to receive information during the fiscal year for monitoring during the post-award process. Review grant and subrecipient activity at year-end to evaluate whether all activity has been submitted and recorded. Views of Responsible Officials: Management agrees with the finding and a response is included in the corrective action plan.
Criteria: According to grant terms & conditions and 2 CFR Section 200.332, all awardees of applicable grants and cooperative agreements are required to report to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) on all subawards over $30,000. Condition: The Commission did not provide timely FFATA reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Context: This is a condition identified based on review of grant terms and conditions and 2 CFR Section 200.332. Cause: The Commission was not aware of this reporting requirement. Effect: The Commission is not in compliance with FFATA reporting requirements for fiscal year 2024. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: We suggest that management review all awards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. Views of Responsible Officials: The Commission agrees with the finding. Planned Corrective Action: The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Sub-awards stating this requirement. Responsible Official: Laura Leach, Director of Finance and Administration Anticipated Completion Date: December 31, 2024
Criteria: According to grant terms & conditions and 2 CFR Section 200.332, all awardees of applicable grants and cooperative agreements are required to report to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) on all subawards over $30,000. Condition: The Commission did not provide timely FFATA reporting for ALN #11.469 and #11.472 subawards subject to the FFATA reporting requirements. Context: This is a condition identified based on review of grant terms and conditions and 2 CFR Section 200.332. Cause: The Commission was not aware of this reporting requirement. Effect: The Commission is not in compliance with FFATA reporting requirements for fiscal year 2024. Identification of a Repeat Finding: This is not a repeat finding. Recommendation: We suggest that management review all awards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. Views of Responsible Officials: The Commission agrees with the finding. Planned Corrective Action: The Commission will review all subawards for subrecipients and ensure that FFATA reporting is completed in a timely manner for subawards subject to the requirements. The Commission will add a clause in our Sub-awards stating this requirement. Responsible Official: Laura Leach, Director of Finance and Administration Anticipated Completion Date: December 31, 2024
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a 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. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.