Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Compliance Requirement Subrecipient monitoring Material Weakness Material Noncompliance 2022-003. The County should establish controls to ensure subrecipients are sufficiently monitored. Assistance Listing Number 21.027 Federal Award Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of the Treasury Pass-through N/A – Direct Award Questioned Costs None Context There was one transaction passed-through to a subrecipient. Repeat Finding No Criteria The Federal Compliance Supplement and 2 CFR Section 200.332 requires pass-through entities to communicate and clearly identify to the subrecipient: 1) the award as a subaward at the time of the subaward by providing the information described in 2 CFR section 200.332(a)(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 terms and conditions of the award; and 3) any additional requirements the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. It also requires the pass-through entity to verify that every subrecipient is audited under the Uniform Guidance when required. Condition The County did not have an effective process in place to ensure required communications occurred with subrecipients of federal awards. There was no agreement with the subrecipient that explicitly included certain information required under 2 CFR 200.332(a)(1). During our audit of the County’s federal expenditures, we noted that the only procedure in place to monitor the subrecipient’s use of federal awards was a visual inspection of the work completed. Cause Management was not aware of the additional communication requirements imposed on pass-through entities. Effect Failure to monitor subrecipient’s use of federal awards could result in the erroneous or fraudulent spending of federal awards, as well as a risk the subrecipient may not be audited in accordance with the Uniform Guidance when required. Recommendation We recommend the County update its communications with the subrecipient to include the required communications of the subrecipient’s responsibilities under the federal requirements, grant agreements and award requirements including, but not limited to its audit obligations under the Uniform Guidance. Views of Responsible Official(s) This payment was a one-time payment for a single project completed by the City of Meridian. Moving forward, Lauderdale County will document the completion of the project.
2022-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – SAPT COVID Supplement ALN 93.959 – Prevention, Women’s Specialty Services, Administration ALN 93.959 – Treatment/AMS Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2022-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – SAPT COVID Supplement ALN 93.959 – Prevention, Women’s Specialty Services, Administration ALN 93.959 – Treatment/AMS Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2022-001 – Communications with Subrecipients Finding Type: Significant Deficiency in internal control over compliance Program: ALN 93.959 – SAPT COVID Supplement ALN 93.959 – Prevention, Women’s Specialty Services, Administration ALN 93.959 – Treatment/AMS Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2022-002: Subrecipient Monitoring Federal Grantor: U.S. Department of Health and Human Services Pass-Through Grantor: Missouri Department of Social Services Federal Assistance Listing Number: 93.558 Program Title: Temporary Assistance for Needy Families Pass-through Entity Identifying Number: CS200821001 Award Year: 2021-2022; 2022-2023 Questioned Costs: None Criteria: The Uniform Guidance at 2 CFR 200.332(d) requires non-federal entities providing federal funds to subrecipients to ?Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward.? As part of the organization?s monitoring procedures, on-site monitoring visits of each subrecipients SkillUp program performance are to be conducted each year to ensure compliance with the state of Missouri SkillUp Provider Handbook. Condition: The organization did not conduct on-site monitoring of SkillUp subrecipients during the fiscal year. Cause: The organization had turnover in the Executive Director and program management positions during the fiscal year. The monitoring is typically performed in the summer but the SkillUp Program Manager left in the summer of 2022 prior to conducting the monitoring, and the process of finding and training a replacement took some time. Effect: The lack of on-site monitoring or the performance of alternative procedures inhibits the organizations ability to ensure that subrecipients are complying with the requirements of the federal program. Recommendation: We recommend that the organization implement internal controls over the subrecipient monitoring process to ensure that on-site visits or adequate alternative procedures are in place to ensure subrecipient compliance with the requirements of federal programs.
FINDING 2022-037 Crime Victim Assistance, ALN 16.575, Subrecipient Monitoring - Risk Assessment and During-the-Award Monitoring See Schedule of Findings and Questioned Costs for chart/table. Condition MDHHS did not sufficiently monitor and evaluate the risk of noncompliance with program requirements. We noted: a. MDHHS did not sufficiently monitor service activity for 3 (14%) of 21 subrecipients during fiscal year 2022. For 2 of the 3 subrecipients, MDHHS did not monitor the service activity for all quarters of fiscal year 2022. For 1 of the 3 subrecipients, MDHHS did not require the subrecipient to provide service activity data for its review. b. MDHHS did not evaluate 1 (5%) of 21 subrecipient's risk of noncompliance with program requirements to determine and implement the type of monitoring appropriate for the subrecipient. Criteria Federal regulation 2 CFR 200.332(d) requires MDHHS to monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. In addition, federal regulation 2 CFR 200.332(b) requires MDHHS to evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. As part of its monitoring procedures, MDHHS reviews subrecipient service activity data. Cause For part a., MDHHS informed us data was reviewed and certified by the grantee, but MDHHS did not document its review in the log. For the service activity data that was not reviewed, MDHHS believed the administrative portion of the Crime Victims Assistance funds did not require service activity reports. For part b., MDHHS informed us it completes its annual risk assessment by November 15 and adjusts its monitoring plan for any awards issued through March 31. The grant agreement commenced May 1, 2022 and continued through September 30, 2022 and, therefore, was not included in the fiscal year 2022 monitoring plan. Effect Insufficient monitoring and evaluation of subrecipients could increase the subrecipients' and MDHHS's noncompliance with federal statutes, regulations, or the terms and conditions of federal awards. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDHHS sufficiently monitor and evaluate the risk of noncompliance with program requirements. Management Views MDHHS agrees with the finding.
FINDING 2022-040 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition MDOT did not ensure its review of subrecipient single audit* reports and issuance of management decisions were completed within six months of the Federal Audit Clearinghouse (FAC) acceptance date. MDOT's process is to begin its review of subrecipient single audits after all applicable audits are received. Therefore, it reviewed the 2020 and 2021 single audits in March 2022 and March and April 2023, respectively. We noted: a. For all 9 sampled 2020 single audits, MDOT's reviews were not timely and ranged between 72 and 229 days late. b. MDOT had not reviewed any of its subrecipient 2021 single audits as of September 30, 2022, which should have been reviewed between June 2022 and September 2022. In addition, MDOT did not issue management decision letters within six months of the FAC acceptance date for 3 subrecipient single audit reports. Each of these reports contained material weaknesses. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521 requires MDOT to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause MDOT informed us an oversight occurred due to employee turnover and the need to update its procedures. Effect MDOT limited the State's assurance its subrecipients complied with grant requirements and implemented corrective action for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to MDOT's records. The federal grantor agency could issue sanctions or disallowance related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDOT ensure its review of subrecipient single audit reports and issuance of management decisions are completed within six months of the FAC acceptance date. Management Views MDOT agrees with the finding.
FINDING 2022-040 Formula Grants for Rural Areas and Tribal Transit Program, ALN 20.509, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition MDOT did not ensure its review of subrecipient single audit* reports and issuance of management decisions were completed within six months of the Federal Audit Clearinghouse (FAC) acceptance date. MDOT's process is to begin its review of subrecipient single audits after all applicable audits are received. Therefore, it reviewed the 2020 and 2021 single audits in March 2022 and March and April 2023, respectively. We noted: a. For all 9 sampled 2020 single audits, MDOT's reviews were not timely and ranged between 72 and 229 days late. b. MDOT had not reviewed any of its subrecipient 2021 single audits as of September 30, 2022, which should have been reviewed between June 2022 and September 2022. In addition, MDOT did not issue management decision letters within six months of the FAC acceptance date for 3 subrecipient single audit reports. Each of these reports contained material weaknesses. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521 requires MDOT to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause MDOT informed us an oversight occurred due to employee turnover and the need to update its procedures. Effect MDOT limited the State's assurance its subrecipients complied with grant requirements and implemented corrective action for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to MDOT's records. The federal grantor agency could issue sanctions or disallowance related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDOT ensure its review of subrecipient single audit reports and issuance of management decisions are completed within six months of the FAC acceptance date. Management Views MDOT agrees with the finding.
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-042 Education Stabilization Fund, ALN 84.425, Subrecipient Monitoring - During-the-Award Monitoring Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not complete sufficient during-the-award monitoring procedures in fiscal year 2022. MDE provided its subrecipients a two-year grant and notified its subrecipients in their grant award notification that a final expenditure report (FER) was due by August 29, 2022. As of September 30, 2022, MDE received 1,335 (78%) of 1,717 FERs for the two-year grant. In addition, MDE contracted with a vendor to conduct desk reviews of ESF subrecipients beginning in July 2022. We noted: a. MDE did not complete any reviews of the FERs submitted during fiscal year 2022. We determined subrecipients submitted 990 (58%) FERs by August 29, 2022. b. Neither MDE nor its contractor could provide documentation supporting the subrecipient desk reviews finalized and whether any corrective action was required or enforcement action was taken against noncompliant subrecipients during fiscal year 2022. Criteria Federal regulation 2 CFR 200.303 requires the nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of federal awards. In addition, federal regulation 2 CFR 200.332(d) states that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward. Federal regulation 2 CFR 200.332(h) states that all pass-through entities must consider taking enforcement action against noncompliant subrecipients. MDE's grant award notifications required ESF subrecipients to submit a FER by August 29, 2022. MDE contracted for the completion of subrecipient desk reviews. Cause MDE elected to delay its review of FERs until all FERs were received. Also, because MDE's contracted desk reviews did not begin until July 2022, it was unable to finalize any individual subrecipient reviews by September 30, 2022. Effect MDE may not identify in a timely manner subrecipients that used funds for unauthorized purposes. We consider this to be a material weakness and material noncompliance because of lack of during-the-award monitoring activities. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE complete sufficient during-the-award monitoring of ESF subrecipients. Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for ESF funds and the ESF program is inherently more flexible than other federal programs in this regard. Although grant award notifications (GANs) originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State's fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State's fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Auditor's Comments to Management Views We determined, and MDE acknowledged, it did not complete any FER reviews or finalize any desk reviews as part of its during-the-award monitoring activities for the $1.8 billion provided to subrecipients in fiscal year 2022. In addition, the contractor acknowledged it did not have a tracking mechanism in place identifying when desk reviews were completed, consequently documentation did not exist to validate MDE's assertion that a majority of the subrecipient monitoring was complete. Federal regulation 2 CFR 200 Subpart F requires the SOM single audit be conducted annually in accordance with the State's fiscal year, which represents the period covered by the auditor's compliance opinion. Therefore, sufficient appropriate evidence must exist during the audit period to determine whether MDE complied with the subrecipient monitoring requirement identified as subject to audit in the OMB Compliance Supplement. Sufficient appropriate evidence did not exist in fiscal year 2022 to support compliance with federal regulation 2 CFR 200.332(d). Therefore, the finding stands as written.
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-042 Education Stabilization Fund, ALN 84.425, Subrecipient Monitoring - During-the-Award Monitoring Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not complete sufficient during-the-award monitoring procedures in fiscal year 2022. MDE provided its subrecipients a two-year grant and notified its subrecipients in their grant award notification that a final expenditure report (FER) was due by August 29, 2022. As of September 30, 2022, MDE received 1,335 (78%) of 1,717 FERs for the two-year grant. In addition, MDE contracted with a vendor to conduct desk reviews of ESF subrecipients beginning in July 2022. We noted: a. MDE did not complete any reviews of the FERs submitted during fiscal year 2022. We determined subrecipients submitted 990 (58%) FERs by August 29, 2022. b. Neither MDE nor its contractor could provide documentation supporting the subrecipient desk reviews finalized and whether any corrective action was required or enforcement action was taken against noncompliant subrecipients during fiscal year 2022. Criteria Federal regulation 2 CFR 200.303 requires the nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of federal awards. In addition, federal regulation 2 CFR 200.332(d) states that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward. Federal regulation 2 CFR 200.332(h) states that all pass-through entities must consider taking enforcement action against noncompliant subrecipients. MDE's grant award notifications required ESF subrecipients to submit a FER by August 29, 2022. MDE contracted for the completion of subrecipient desk reviews. Cause MDE elected to delay its review of FERs until all FERs were received. Also, because MDE's contracted desk reviews did not begin until July 2022, it was unable to finalize any individual subrecipient reviews by September 30, 2022. Effect MDE may not identify in a timely manner subrecipients that used funds for unauthorized purposes. We consider this to be a material weakness and material noncompliance because of lack of during-the-award monitoring activities. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE complete sufficient during-the-award monitoring of ESF subrecipients. Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for ESF funds and the ESF program is inherently more flexible than other federal programs in this regard. Although grant award notifications (GANs) originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State's fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State's fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Auditor's Comments to Management Views We determined, and MDE acknowledged, it did not complete any FER reviews or finalize any desk reviews as part of its during-the-award monitoring activities for the $1.8 billion provided to subrecipients in fiscal year 2022. In addition, the contractor acknowledged it did not have a tracking mechanism in place identifying when desk reviews were completed, consequently documentation did not exist to validate MDE's assertion that a majority of the subrecipient monitoring was complete. Federal regulation 2 CFR 200 Subpart F requires the SOM single audit be conducted annually in accordance with the State's fiscal year, which represents the period covered by the auditor's compliance opinion. Therefore, sufficient appropriate evidence must exist during the audit period to determine whether MDE complied with the subrecipient monitoring requirement identified as subject to audit in the OMB Compliance Supplement. Sufficient appropriate evidence did not exist in fiscal year 2022 to support compliance with federal regulation 2 CFR 200.332(d). Therefore, the finding stands as written.
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-042 Education Stabilization Fund, ALN 84.425, Subrecipient Monitoring - During-the-Award Monitoring Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not complete sufficient during-the-award monitoring procedures in fiscal year 2022. MDE provided its subrecipients a two-year grant and notified its subrecipients in their grant award notification that a final expenditure report (FER) was due by August 29, 2022. As of September 30, 2022, MDE received 1,335 (78%) of 1,717 FERs for the two-year grant. In addition, MDE contracted with a vendor to conduct desk reviews of ESF subrecipients beginning in July 2022. We noted: a. MDE did not complete any reviews of the FERs submitted during fiscal year 2022. We determined subrecipients submitted 990 (58%) FERs by August 29, 2022. b. Neither MDE nor its contractor could provide documentation supporting the subrecipient desk reviews finalized and whether any corrective action was required or enforcement action was taken against noncompliant subrecipients during fiscal year 2022. Criteria Federal regulation 2 CFR 200.303 requires the nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of federal awards. In addition, federal regulation 2 CFR 200.332(d) states that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward. Federal regulation 2 CFR 200.332(h) states that all pass-through entities must consider taking enforcement action against noncompliant subrecipients. MDE's grant award notifications required ESF subrecipients to submit a FER by August 29, 2022. MDE contracted for the completion of subrecipient desk reviews. Cause MDE elected to delay its review of FERs until all FERs were received. Also, because MDE's contracted desk reviews did not begin until July 2022, it was unable to finalize any individual subrecipient reviews by September 30, 2022. Effect MDE may not identify in a timely manner subrecipients that used funds for unauthorized purposes. We consider this to be a material weakness and material noncompliance because of lack of during-the-award monitoring activities. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE complete sufficient during-the-award monitoring of ESF subrecipients. Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for ESF funds and the ESF program is inherently more flexible than other federal programs in this regard. Although grant award notifications (GANs) originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State's fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State's fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Auditor's Comments to Management Views We determined, and MDE acknowledged, it did not complete any FER reviews or finalize any desk reviews as part of its during-the-award monitoring activities for the $1.8 billion provided to subrecipients in fiscal year 2022. In addition, the contractor acknowledged it did not have a tracking mechanism in place identifying when desk reviews were completed, consequently documentation did not exist to validate MDE's assertion that a majority of the subrecipient monitoring was complete. Federal regulation 2 CFR 200 Subpart F requires the SOM single audit be conducted annually in accordance with the State's fiscal year, which represents the period covered by the auditor's compliance opinion. Therefore, sufficient appropriate evidence must exist during the audit period to determine whether MDE complied with the subrecipient monitoring requirement identified as subject to audit in the OMB Compliance Supplement. Sufficient appropriate evidence did not exist in fiscal year 2022 to support compliance with federal regulation 2 CFR 200.332(d). Therefore, the finding stands as written.
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-042 Education Stabilization Fund, ALN 84.425, Subrecipient Monitoring - During-the-Award Monitoring Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not complete sufficient during-the-award monitoring procedures in fiscal year 2022. MDE provided its subrecipients a two-year grant and notified its subrecipients in their grant award notification that a final expenditure report (FER) was due by August 29, 2022. As of September 30, 2022, MDE received 1,335 (78%) of 1,717 FERs for the two-year grant. In addition, MDE contracted with a vendor to conduct desk reviews of ESF subrecipients beginning in July 2022. We noted: a. MDE did not complete any reviews of the FERs submitted during fiscal year 2022. We determined subrecipients submitted 990 (58%) FERs by August 29, 2022. b. Neither MDE nor its contractor could provide documentation supporting the subrecipient desk reviews finalized and whether any corrective action was required or enforcement action was taken against noncompliant subrecipients during fiscal year 2022. Criteria Federal regulation 2 CFR 200.303 requires the nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of federal awards. In addition, federal regulation 2 CFR 200.332(d) states that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward. Federal regulation 2 CFR 200.332(h) states that all pass-through entities must consider taking enforcement action against noncompliant subrecipients. MDE's grant award notifications required ESF subrecipients to submit a FER by August 29, 2022. MDE contracted for the completion of subrecipient desk reviews. Cause MDE elected to delay its review of FERs until all FERs were received. Also, because MDE's contracted desk reviews did not begin until July 2022, it was unable to finalize any individual subrecipient reviews by September 30, 2022. Effect MDE may not identify in a timely manner subrecipients that used funds for unauthorized purposes. We consider this to be a material weakness and material noncompliance because of lack of during-the-award monitoring activities. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE complete sufficient during-the-award monitoring of ESF subrecipients. Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for ESF funds and the ESF program is inherently more flexible than other federal programs in this regard. Although grant award notifications (GANs) originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State's fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State's fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Auditor's Comments to Management Views We determined, and MDE acknowledged, it did not complete any FER reviews or finalize any desk reviews as part of its during-the-award monitoring activities for the $1.8 billion provided to subrecipients in fiscal year 2022. In addition, the contractor acknowledged it did not have a tracking mechanism in place identifying when desk reviews were completed, consequently documentation did not exist to validate MDE's assertion that a majority of the subrecipient monitoring was complete. Federal regulation 2 CFR 200 Subpart F requires the SOM single audit be conducted annually in accordance with the State's fiscal year, which represents the period covered by the auditor's compliance opinion. Therefore, sufficient appropriate evidence must exist during the audit period to determine whether MDE complied with the subrecipient monitoring requirement identified as subject to audit in the OMB Compliance Supplement. Sufficient appropriate evidence did not exist in fiscal year 2022 to support compliance with federal regulation 2 CFR 200.332(d). Therefore, the finding stands as written.
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-042 Education Stabilization Fund, ALN 84.425, Subrecipient Monitoring - During-the-Award Monitoring Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not complete sufficient during-the-award monitoring procedures in fiscal year 2022. MDE provided its subrecipients a two-year grant and notified its subrecipients in their grant award notification that a final expenditure report (FER) was due by August 29, 2022. As of September 30, 2022, MDE received 1,335 (78%) of 1,717 FERs for the two-year grant. In addition, MDE contracted with a vendor to conduct desk reviews of ESF subrecipients beginning in July 2022. We noted: a. MDE did not complete any reviews of the FERs submitted during fiscal year 2022. We determined subrecipients submitted 990 (58%) FERs by August 29, 2022. b. Neither MDE nor its contractor could provide documentation supporting the subrecipient desk reviews finalized and whether any corrective action was required or enforcement action was taken against noncompliant subrecipients during fiscal year 2022. Criteria Federal regulation 2 CFR 200.303 requires the nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of federal awards. In addition, federal regulation 2 CFR 200.332(d) states that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward. Federal regulation 2 CFR 200.332(h) states that all pass-through entities must consider taking enforcement action against noncompliant subrecipients. MDE's grant award notifications required ESF subrecipients to submit a FER by August 29, 2022. MDE contracted for the completion of subrecipient desk reviews. Cause MDE elected to delay its review of FERs until all FERs were received. Also, because MDE's contracted desk reviews did not begin until July 2022, it was unable to finalize any individual subrecipient reviews by September 30, 2022. Effect MDE may not identify in a timely manner subrecipients that used funds for unauthorized purposes. We consider this to be a material weakness and material noncompliance because of lack of during-the-award monitoring activities. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE complete sufficient during-the-award monitoring of ESF subrecipients. Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for ESF funds and the ESF program is inherently more flexible than other federal programs in this regard. Although grant award notifications (GANs) originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State's fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State's fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Auditor's Comments to Management Views We determined, and MDE acknowledged, it did not complete any FER reviews or finalize any desk reviews as part of its during-the-award monitoring activities for the $1.8 billion provided to subrecipients in fiscal year 2022. In addition, the contractor acknowledged it did not have a tracking mechanism in place identifying when desk reviews were completed, consequently documentation did not exist to validate MDE's assertion that a majority of the subrecipient monitoring was complete. Federal regulation 2 CFR 200 Subpart F requires the SOM single audit be conducted annually in accordance with the State's fiscal year, which represents the period covered by the auditor's compliance opinion. Therefore, sufficient appropriate evidence must exist during the audit period to determine whether MDE complied with the subrecipient monitoring requirement identified as subject to audit in the OMB Compliance Supplement. Sufficient appropriate evidence did not exist in fiscal year 2022 to support compliance with federal regulation 2 CFR 200.332(d). Therefore, the finding stands as written.
FINDING 2022-018 MDE, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDE did not report one or more of the following for 4 (16%) of 25 sampled Supporting Effective Instruction State Grant subrecipients and 28 (47%) of 60 ESF subrecipients: unique entity identifier, FAIN, federal award date, federal award project description, name of federal awarding agency and pass-through entity, ALN, Assistance Listing Title, federal award dollar amount, identification of whether the award is research and development, indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and closeout terms and conditions. b. MDE did not report the correct FAIN or closeout terms and conditions for all 5 sampled Coronavirus State and Local Fiscal Recovery Funds subrecipients. Criteria Federal regulation 2 CFR 200.332(a) requires that all pass-through entities ensure that every subaward includes certain information. Cause For part a., MDE informed us MEGS+ is designed to automatically generate the grant award notifications upon approval of subaward applications; however, this function did not operate correctly in fiscal year 2022. For part b., MDE informed us because of an oversight, it did not always provide all required subaward information to subrecipients. Also, MDE believed it used the best available information at the time MDE developed and executed the subawards; however, our review of documentation noted MDE was provided the program's award identification prior to the executed subawards, but MDE staff did not appropriately communicate the information to applicable parties. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. We consider this to be a material weakness and material noncompliance for ESF because of the high error rate related to federal award information which was not disclosed to the subrecipient. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views MDE agrees with the finding
FINDING 2022-042 Education Stabilization Fund, ALN 84.425, Subrecipient Monitoring - During-the-Award Monitoring Procedures See Schedule of Findings and Questioned Costs for chart/table. Condition MDE did not complete sufficient during-the-award monitoring procedures in fiscal year 2022. MDE provided its subrecipients a two-year grant and notified its subrecipients in their grant award notification that a final expenditure report (FER) was due by August 29, 2022. As of September 30, 2022, MDE received 1,335 (78%) of 1,717 FERs for the two-year grant. In addition, MDE contracted with a vendor to conduct desk reviews of ESF subrecipients beginning in July 2022. We noted: a. MDE did not complete any reviews of the FERs submitted during fiscal year 2022. We determined subrecipients submitted 990 (58%) FERs by August 29, 2022. b. Neither MDE nor its contractor could provide documentation supporting the subrecipient desk reviews finalized and whether any corrective action was required or enforcement action was taken against noncompliant subrecipients during fiscal year 2022. Criteria Federal regulation 2 CFR 200.303 requires the nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of federal awards. In addition, federal regulation 2 CFR 200.332(d) states that all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address single audit findings related to the particular subaward. Federal regulation 2 CFR 200.332(h) states that all pass-through entities must consider taking enforcement action against noncompliant subrecipients. MDE's grant award notifications required ESF subrecipients to submit a FER by August 29, 2022. MDE contracted for the completion of subrecipient desk reviews. Cause MDE elected to delay its review of FERs until all FERs were received. Also, because MDE's contracted desk reviews did not begin until July 2022, it was unable to finalize any individual subrecipient reviews by September 30, 2022. Effect MDE may not identify in a timely manner subrecipients that used funds for unauthorized purposes. We consider this to be a material weakness and material noncompliance because of lack of during-the-award monitoring activities. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDE complete sufficient during-the-award monitoring of ESF subrecipients. Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for ESF funds and the ESF program is inherently more flexible than other federal programs in this regard. Although grant award notifications (GANs) originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State's fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State's fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Auditor's Comments to Management Views We determined, and MDE acknowledged, it did not complete any FER reviews or finalize any desk reviews as part of its during-the-award monitoring activities for the $1.8 billion provided to subrecipients in fiscal year 2022. In addition, the contractor acknowledged it did not have a tracking mechanism in place identifying when desk reviews were completed, consequently documentation did not exist to validate MDE's assertion that a majority of the subrecipient monitoring was complete. Federal regulation 2 CFR 200 Subpart F requires the SOM single audit be conducted annually in accordance with the State's fiscal year, which represents the period covered by the auditor's compliance opinion. Therefore, sufficient appropriate evidence must exist during the audit period to determine whether MDE complied with the subrecipient monitoring requirement identified as subject to audit in the OMB Compliance Supplement. Sufficient appropriate evidence did not exist in fiscal year 2022 to support compliance with federal regulation 2 CFR 200.332(d). Therefore, the finding stands as written.
FINDING 2022-061 Disaster Grants - Public Assistance (Presidentially Declared Disasters), ALN 97.036, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition MSP did not appropriately monitor its subrecipients to ensure they complied with the Uniform Guidance. MSP utilized a tracking sheet to identify those subrecipients that required a single audit and a form to document its review of subrecipient single audits. We sampled 5 subrecipients and noted for 2 (40%): a. MSP did not appropriately identify or document if the subrecipients required a single audit. Therefore, MSP did not monitor these subrecipients to ensure the status or submission of their single audit reports. We verified both subrecipients obtained the required single audits. b. MSP did not complete single audit report review forms. Therefore, MSP did not take steps to determine whether a management decision letter was needed. We verified there were no findings related to both subrecipients' federal awards. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521(d) requires MSP to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause MSP informed us a miscommunication between its staff regarding its query of subrecipient expenditure data resulted in subrecipients being excluded from the tracking sheet. Effect MSP limited the State's assurance that its subrecipients complied with grant requirements and implemented corrective actions for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to MSP's records. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MSP appropriately monitor its subrecipients to ensure they comply with the Uniform Guidance. Management Views MSP agrees with the finding.
FINDING 2022-061 Disaster Grants - Public Assistance (Presidentially Declared Disasters), ALN 97.036, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition MSP did not appropriately monitor its subrecipients to ensure they complied with the Uniform Guidance. MSP utilized a tracking sheet to identify those subrecipients that required a single audit and a form to document its review of subrecipient single audits. We sampled 5 subrecipients and noted for 2 (40%): a. MSP did not appropriately identify or document if the subrecipients required a single audit. Therefore, MSP did not monitor these subrecipients to ensure the status or submission of their single audit reports. We verified both subrecipients obtained the required single audits. b. MSP did not complete single audit report review forms. Therefore, MSP did not take steps to determine whether a management decision letter was needed. We verified there were no findings related to both subrecipients' federal awards. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521(d) requires MSP to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause MSP informed us a miscommunication between its staff regarding its query of subrecipient expenditure data resulted in subrecipients being excluded from the tracking sheet. Effect MSP limited the State's assurance that its subrecipients complied with grant requirements and implemented corrective actions for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to MSP's records. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MSP appropriately monitor its subrecipients to ensure they comply with the Uniform Guidance. Management Views MSP agrees with the finding.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, beneficiary eligibility, period of performance, reporting, subrecipient monitoring, and special tests and provisions. The related compliance requirements are set in Section 501 of Division N of the Consolidated Appropriations Act, 2021, 2 CFR Part 200, Subpart E, Appendices III-V11, and sections 200.330, .331, and .501(h), federal awarding agency regulations, and the terms and conditions of the award. Condition: Subrecipient monitoring controls related to periodic subrecipient reports and the final subrecipient expenditure reports, financial reporting, period of performance, and special tests and provisions for funding reallocations were not documented in a manner that is reperformable. Cause: Control activities were performed informally and without clear documentation. Effect: Individuals who are not eligible to receive the services funded by this grant may incorrectly be served by the subrecipient entities, allowable costs or cost principles may not have been followed by subrecipient entities, or subrecipients may not have been properly monitored for other compliance requirements. Expenditures could be made outside of the period of performance, amounts in the financial reports could be incorrect, funding reallocation requirements could be missed. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
Criteria: 2 CFR Part 200 in general and 2 CFR section 200.332 require non-Federal entities to establish and maintain effective internal controls over Federal awards, including the requirements for allowable costs, cost principles, reporting, and suspension and debarment. The related compliance requirements are set in 2 CFR Part 200 sections 200.514(c), 200.212, 200.318(h), 180.300 and subpart E; 48 CFR section 52.209-6; 31 CFR section 19.300; sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021, Pub. L. No. 117-2 as codified at 42 USC 802 and 803 and 31 CFR Part 35, federal awarding agency regulations, and the terms and conditions of the award. Condition: Controls related to calculation and reporting of lost revenue were not effective and the amount calculated as base year revenue was incorrectly reported. Controls related to reporting of other grant expenditures were not effective and certain amounts were missing from the financial reports. Controls related to ensuring contractors were not suspended, debarred, or otherwise excluded pursuant to 31 CFR section 19.300 were not documented in a manner that is reperformable. Cause: Base year calculation of revenue was performed using interim financial information and was not reconciled to final audited reports. Base year calculation of revenue was not clearly documented. Subsequent year revenue calculations were performed by a consultant who was not engaged to review the base year calculation. Controls over such calculations were not effective. Review of financial reports was not sufficient to ensure all grant expenditures were reported. Suspension and debarment controls were not evidenced with clear documentation; checklists are maintained but were not completed in all cases. Effect: Calculation of lost revenue was incorrectly reported. Expenditures related to the provision of government services related to such lost revenue did not exceed the actual lost revenue. Certain other grant expenditures were erroneously excluded from the financial reports. Procurement of contractors risks including those who were suspended or debarred; however none such were identified. Recommendation: We recommend that the City ensure that all controls for grants be documented in written procedures which should include the name or title of the positions responsible for each control (preparation, review, reconciliation, etc.) and that the performance of the controls be documented in a clear, reperformable manner including the name and date of each responsible individual and which specific control they performed over compliance for the grant.
2022-001: Considered a significant deficiency in internal control over compliance/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Prevention, COVID-19 Prevention II, and COVID-19 ARPA Prevention) Criteria: As detailed by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: During testing of contracts with subrecipients it was noted that these contracts did not include portions of required disclosures. Cause/Effect: This condition appears to be the result of inconsistent application of internal controls over compliance. Contracts with subrecipients were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2022-001: Considered a significant deficiency in internal control over compliance/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Prevention, COVID-19 Prevention II, and COVID-19 ARPA Prevention) Criteria: As detailed by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: During testing of contracts with subrecipients it was noted that these contracts did not include portions of required disclosures. Cause/Effect: This condition appears to be the result of inconsistent application of internal controls over compliance. Contracts with subrecipients were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
2022-001: Considered a significant deficiency in internal control over compliance/immaterial non-compliance Program: ALN 93.959 Block Grants for Prevention and Treatment of Substance Abuse (Prevention, COVID-19 Prevention II, and COVID-19 ARPA Prevention) Criteria: As detailed by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: During testing of contracts with subrecipients it was noted that these contracts did not include portions of required disclosures. Cause/Effect: This condition appears to be the result of inconsistent application of internal controls over compliance. Contracts with subrecipients were not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the Entity update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
Finding No. 2022-001 (Repeat of 2021-004): Identifying Federal Award Information of Pass-Through Funds to Subrecipients Assistance Listing Program Title and Number: Special Programs for the Aging - Title III, Part B - Grants for Supportive Services and Senior Centers 93.044 Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 ? American Rescue Plan Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 - Consolidated Appropriations Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 Nutrition Services Incentive Program 93.053 Special Programs for the Aging - Title III, Part D - Disease Prevention and Health Promotion Services 93.043 National Family Caregiver Support - Title III, Part E 93.052 Social Services Block Grant 93.667 Coronavirus Relief Fund 21.019 Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: State of Connecticut Department of Aging and Disability Services Criteria As per 2 CFR Section 200.332, a pass-through entity must clearly identify to the subrecipient: (1) the award as a subaward at the time of the subaward by providing information described in 2 CFR Section 200.332; (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. Condition The audited financial statements of subrecipients reviewed during the audit did not appropriately identify federal subawards passed through by the Agency. Cause The Agency did not properly communicate federal subaward information to subrecipients. Effect The financial statements of the subrecipients did not accurately identify federal subaward information. Questioned Costs None. Context The Agency did not have a formalized process to communicate federal subaward information to subrecipient organizations. Recommendation We recommend that all necessary efforts be taken to identify and communicate the federal subaward information for funds passed through to subrecipients. This includes a recommendation that the Agency verifies that the reported expenditures for funds passed through to subrecipients is in agreement with the federal subaward information as reported on the financial statements of the subrecipients. Views of Responsible Officials In the past, the Agency provided confirmations to subrecipients as requested. Going forward, the source of funding along with the breakout by financial assistance listing number will be clearly communicated to all subrecipients. The Agency will also ensure that reported expenditures by each subrecipient reconciles to the Agency?s advances to that subrecipient during the review of the subrecipient audit reports.
Finding No. 2022-001 (Repeat of 2021-004): Identifying Federal Award Information of Pass-Through Funds to Subrecipients Assistance Listing Program Title and Number: Special Programs for the Aging - Title III, Part B - Grants for Supportive Services and Senior Centers 93.044 Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 ? American Rescue Plan Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 - Consolidated Appropriations Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 Nutrition Services Incentive Program 93.053 Special Programs for the Aging - Title III, Part D - Disease Prevention and Health Promotion Services 93.043 National Family Caregiver Support - Title III, Part E 93.052 Social Services Block Grant 93.667 Coronavirus Relief Fund 21.019 Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: State of Connecticut Department of Aging and Disability Services Criteria As per 2 CFR Section 200.332, a pass-through entity must clearly identify to the subrecipient: (1) the award as a subaward at the time of the subaward by providing information described in 2 CFR Section 200.332; (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. Condition The audited financial statements of subrecipients reviewed during the audit did not appropriately identify federal subawards passed through by the Agency. Cause The Agency did not properly communicate federal subaward information to subrecipients. Effect The financial statements of the subrecipients did not accurately identify federal subaward information. Questioned Costs None. Context The Agency did not have a formalized process to communicate federal subaward information to subrecipient organizations. Recommendation We recommend that all necessary efforts be taken to identify and communicate the federal subaward information for funds passed through to subrecipients. This includes a recommendation that the Agency verifies that the reported expenditures for funds passed through to subrecipients is in agreement with the federal subaward information as reported on the financial statements of the subrecipients. Views of Responsible Officials In the past, the Agency provided confirmations to subrecipients as requested. Going forward, the source of funding along with the breakout by financial assistance listing number will be clearly communicated to all subrecipients. The Agency will also ensure that reported expenditures by each subrecipient reconciles to the Agency?s advances to that subrecipient during the review of the subrecipient audit reports.
Finding No. 2022-001 (Repeat of 2021-004): Identifying Federal Award Information of Pass-Through Funds to Subrecipients Assistance Listing Program Title and Number: Special Programs for the Aging - Title III, Part B - Grants for Supportive Services and Senior Centers 93.044 Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 ? American Rescue Plan Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 - Consolidated Appropriations Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 Nutrition Services Incentive Program 93.053 Special Programs for the Aging - Title III, Part D - Disease Prevention and Health Promotion Services 93.043 National Family Caregiver Support - Title III, Part E 93.052 Social Services Block Grant 93.667 Coronavirus Relief Fund 21.019 Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: State of Connecticut Department of Aging and Disability Services Criteria As per 2 CFR Section 200.332, a pass-through entity must clearly identify to the subrecipient: (1) the award as a subaward at the time of the subaward by providing information described in 2 CFR Section 200.332; (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. Condition The audited financial statements of subrecipients reviewed during the audit did not appropriately identify federal subawards passed through by the Agency. Cause The Agency did not properly communicate federal subaward information to subrecipients. Effect The financial statements of the subrecipients did not accurately identify federal subaward information. Questioned Costs None. Context The Agency did not have a formalized process to communicate federal subaward information to subrecipient organizations. Recommendation We recommend that all necessary efforts be taken to identify and communicate the federal subaward information for funds passed through to subrecipients. This includes a recommendation that the Agency verifies that the reported expenditures for funds passed through to subrecipients is in agreement with the federal subaward information as reported on the financial statements of the subrecipients. Views of Responsible Officials In the past, the Agency provided confirmations to subrecipients as requested. Going forward, the source of funding along with the breakout by financial assistance listing number will be clearly communicated to all subrecipients. The Agency will also ensure that reported expenditures by each subrecipient reconciles to the Agency?s advances to that subrecipient during the review of the subrecipient audit reports.
Finding No. 2022-001 (Repeat of 2021-004): Identifying Federal Award Information of Pass-Through Funds to Subrecipients Assistance Listing Program Title and Number: Special Programs for the Aging - Title III, Part B - Grants for Supportive Services and Senior Centers 93.044 Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 ? American Rescue Plan Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 - Consolidated Appropriations Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 Nutrition Services Incentive Program 93.053 Special Programs for the Aging - Title III, Part D - Disease Prevention and Health Promotion Services 93.043 National Family Caregiver Support - Title III, Part E 93.052 Social Services Block Grant 93.667 Coronavirus Relief Fund 21.019 Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: State of Connecticut Department of Aging and Disability Services Criteria As per 2 CFR Section 200.332, a pass-through entity must clearly identify to the subrecipient: (1) the award as a subaward at the time of the subaward by providing information described in 2 CFR Section 200.332; (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. Condition The audited financial statements of subrecipients reviewed during the audit did not appropriately identify federal subawards passed through by the Agency. Cause The Agency did not properly communicate federal subaward information to subrecipients. Effect The financial statements of the subrecipients did not accurately identify federal subaward information. Questioned Costs None. Context The Agency did not have a formalized process to communicate federal subaward information to subrecipient organizations. Recommendation We recommend that all necessary efforts be taken to identify and communicate the federal subaward information for funds passed through to subrecipients. This includes a recommendation that the Agency verifies that the reported expenditures for funds passed through to subrecipients is in agreement with the federal subaward information as reported on the financial statements of the subrecipients. Views of Responsible Officials In the past, the Agency provided confirmations to subrecipients as requested. Going forward, the source of funding along with the breakout by financial assistance listing number will be clearly communicated to all subrecipients. The Agency will also ensure that reported expenditures by each subrecipient reconciles to the Agency?s advances to that subrecipient during the review of the subrecipient audit reports.
Finding No. 2022-001 (Repeat of 2021-004): Identifying Federal Award Information of Pass-Through Funds to Subrecipients Assistance Listing Program Title and Number: Special Programs for the Aging - Title III, Part B - Grants for Supportive Services and Senior Centers 93.044 Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 ? American Rescue Plan Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 - Consolidated Appropriations Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 Nutrition Services Incentive Program 93.053 Special Programs for the Aging - Title III, Part D - Disease Prevention and Health Promotion Services 93.043 National Family Caregiver Support - Title III, Part E 93.052 Social Services Block Grant 93.667 Coronavirus Relief Fund 21.019 Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: State of Connecticut Department of Aging and Disability Services Criteria As per 2 CFR Section 200.332, a pass-through entity must clearly identify to the subrecipient: (1) the award as a subaward at the time of the subaward by providing information described in 2 CFR Section 200.332; (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. Condition The audited financial statements of subrecipients reviewed during the audit did not appropriately identify federal subawards passed through by the Agency. Cause The Agency did not properly communicate federal subaward information to subrecipients. Effect The financial statements of the subrecipients did not accurately identify federal subaward information. Questioned Costs None. Context The Agency did not have a formalized process to communicate federal subaward information to subrecipient organizations. Recommendation We recommend that all necessary efforts be taken to identify and communicate the federal subaward information for funds passed through to subrecipients. This includes a recommendation that the Agency verifies that the reported expenditures for funds passed through to subrecipients is in agreement with the federal subaward information as reported on the financial statements of the subrecipients. Views of Responsible Officials In the past, the Agency provided confirmations to subrecipients as requested. Going forward, the source of funding along with the breakout by financial assistance listing number will be clearly communicated to all subrecipients. The Agency will also ensure that reported expenditures by each subrecipient reconciles to the Agency?s advances to that subrecipient during the review of the subrecipient audit reports.
Finding No. 2022-001 (Repeat of 2021-004): Identifying Federal Award Information of Pass-Through Funds to Subrecipients Assistance Listing Program Title and Number: Special Programs for the Aging - Title III, Part B - Grants for Supportive Services and Senior Centers 93.044 Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 ? American Rescue Plan Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 COVID-19 - Consolidated Appropriations Act for Special Programs for the Aging - Title III, Part C - Nutrition Services 93.045 Nutrition Services Incentive Program 93.053 Special Programs for the Aging - Title III, Part D - Disease Prevention and Health Promotion Services 93.043 National Family Caregiver Support - Title III, Part E 93.052 Social Services Block Grant 93.667 Coronavirus Relief Fund 21.019 Federal Agency: U.S. Department of Health and Human Services Pass-through Entity: State of Connecticut Department of Aging and Disability Services Criteria As per 2 CFR Section 200.332, a pass-through entity must clearly identify to the subrecipient: (1) the award as a subaward at the time of the subaward by providing information described in 2 CFR Section 200.332; (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. Condition The audited financial statements of subrecipients reviewed during the audit did not appropriately identify federal subawards passed through by the Agency. Cause The Agency did not properly communicate federal subaward information to subrecipients. Effect The financial statements of the subrecipients did not accurately identify federal subaward information. Questioned Costs None. Context The Agency did not have a formalized process to communicate federal subaward information to subrecipient organizations. Recommendation We recommend that all necessary efforts be taken to identify and communicate the federal subaward information for funds passed through to subrecipients. This includes a recommendation that the Agency verifies that the reported expenditures for funds passed through to subrecipients is in agreement with the federal subaward information as reported on the financial statements of the subrecipients. Views of Responsible Officials In the past, the Agency provided confirmations to subrecipients as requested. Going forward, the source of funding along with the breakout by financial assistance listing number will be clearly communicated to all subrecipients. The Agency will also ensure that reported expenditures by each subrecipient reconciles to the Agency?s advances to that subrecipient during the review of the subrecipient audit reports.