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.
Significant deficiency in internal controls over compliance and instances of noncompliance related to subrecipient monitoring. Federal Agency: Department of Health and Human Services Program Title: National Organizations of State and Local Officials CFDA Number: 93.011 Award Numbers: 1 G32HS42592-01-00 Award Period: July 31, 2021 - July 31, 2023 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D (as codified by the Department of Health and Human Services [DHHS] in 45 CFR 75) requires a pass-through entity to adopt compliance policies to ensure sub-recipients comply with requirements under the award, and evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of such agreements for the purposes of determining appropriate subrecipient monitoring. Condition/Context for Evaluation In a population of three subrecipients, no documentation was available showing an assessment of the risk of noncompliance of the subrecipients. For one subrecipient, a fixed fee award was issued that had not received prior approval by the federal funder. As such, when the payment to the subrecipient was made based on a fixed amount, the Organization was not monitoring to ensure the subrecipient was minimizing the time lapse between the receipt of payment and expenditures incurred. Questioned Costs Not applicable. Cause The Organization?s subrecipient monitoring policy did not include all the required provisions outlined in 2 CFR 200.332. Effect or Potential Effect The Organization did not fully comply with the requirements regarding subrecipient monitoring. Repeat Finding Not applicable. Recommendation We recommend that the Organization update the subrecipient monitoring policy to ensure a risk assessment is performed over all subrecipients and that any fixed fee awards receive prior approval from the federal funder. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying corrective action plan.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Federal Award Identification Number and Year: M22-SG350100 & M21-SP350100 - 2022 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: A pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: ? Reviewing financial and programmatic (performance and special reports) required by the PTE. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. ? Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition: During our testing, we noted the Authority did not have adequate internal controls designed to properly monitor its? subrecipients. Questioned costs: None Context: During our testing of subrecipient monitoring, it was noted that there was not proper follow up conducted for 3 out of 8 subrecipients tested. The Authority did not follow its policies and procedures to ensure findings and questions were properly addressed by the subrecipient. The sample was a statistically valid sample. Cause: The Authority does not have a policy in place to ensure that subrecipients were responding to its monitoring reports in a timely manner. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance by subrecipients of the grant. Recommendation: We recommend the Authority design controls to ensure subrecipients are responding to and addressing questions and findings within its monitoring reports. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The Authority uses the Tracker database to track monitoring deadlines electronically. The Tracker automatically sends reminders to all staff in the department every two weeks to follow up with pending and outstanding monitoring issues. However, some staff were not using the Tracker as intended. The Director will enforce and monitor the use of the Tracker and ensure staff follow up on the monitorings by the required deadlines. Name of the contact person responsible for corrective action: Chief Housing Officer Planned completion date for corrective action plan: November 30, 2022
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Federal Award Identification Number and Year: M22-SG350100 & M21-SP350100 - 2022 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: A pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: ? Reviewing financial and programmatic (performance and special reports) required by the PTE. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. ? Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition: During our testing, we noted the Authority did not have adequate internal controls designed to properly monitor its? subrecipients. Questioned costs: None Context: During our testing of subrecipient monitoring, it was noted that there was not proper follow up conducted for 3 out of 8 subrecipients tested. The Authority did not follow its policies and procedures to ensure findings and questions were properly addressed by the subrecipient. The sample was a statistically valid sample. Cause: The Authority does not have a policy in place to ensure that subrecipients were responding to its monitoring reports in a timely manner. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance by subrecipients of the grant. Recommendation: We recommend the Authority design controls to ensure subrecipients are responding to and addressing questions and findings within its monitoring reports. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The Authority uses the Tracker database to track monitoring deadlines electronically. The Tracker automatically sends reminders to all staff in the department every two weeks to follow up with pending and outstanding monitoring issues. However, some staff were not using the Tracker as intended. The Director will enforce and monitor the use of the Tracker and ensure staff follow up on the monitorings by the required deadlines. Name of the contact person responsible for corrective action: Chief Housing Officer Planned completion date for corrective action plan: November 30, 2022
Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: ARRA Tax Credit Assistance Program (TCAP) Assistance Listing Number: 14.258 Federal Award Identification Number and Year: M-09-ES-35-0100 - 2022 Award Period: October 1, 2021 through September 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: A pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: ? Reviewing financial and programmatic (performance and special reports) required by the PTE. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. ? Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Criteria or specific requirement (Continued): Grantees must perform asset management functions, or contract for performance of these services at the owner?s expense, to ensure compliance with Section 42 of the IRC and with the long term viability of projects funded by TCAP (ARRA, 123 Stat. 221). Condition: During our testing, we noted the Authority did not have adequate internal controls designed to properly monitor its? subrecipients. Questioned costs: None Context: During our testing of subrecipient monitoring, it was noted that there was not proper follow up conducted for one out of five subrecipients tested. The Authority did not follow its policies and procedures to ensure findings and questions were properly addressed by the subrecipient. The sample was a statistically valid sample. Cause: The Authority does not have a policy in place to ensure that subrecipients were responding to its monitoring reports in a timely manner. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance by subrecipients of the grant. Recommendation: We recommend the Authority design controls to ensure subrecipients are responding to and addressing questions and findings within its monitoring reports. Views of responsible officials and planned corrective actions: There is no disagreement with the audit finding. The Authority uses the Tracker database to track monitoring deadlines electronically. The Tracker automatically sends reminders to all staff in the department every two weeks to follow up with pending and outstanding monitoring issues. However, some staff were not using the Tracker as intended. The Director will enforce and monitor the use of the Tracker and ensure staff follow up on the monitorings by the required deadlines. Name of the contact person responsible for corrective action: Chief Housing Officer Planned completion date for corrective action plan: November 30, 2022
Finding 2022-001:U.S. Department of the Treasury Federal Financial Assistance Listing 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Controls over Compliance and Material Noncompliance Criteria: Per 2 CFR 200.332, pass-through entities must clearly identify required subaward elements to subrecipients, evaluate the subrecipient?s risk of noncompliance with Federal guidelines and the terms of the award, and confirm that the subrecipient is not debarred or suspended. Further, per 2 CFR 200.303, the entity must have a system of internal control designed to maintain compliance with these requirements. Condition: The County provided a subaward of SLFRF funds to a subrecipient. The County did not include the required data elements in the subaward document, did not perform an assessment of the risk of subrecipient noncompliance with federal guidelines and grant terms, and did not review to determine that the subrecipient was not suspended or debarred. Cause: The County did not have a subrecipient monitoring policy in place that required compliance with these guidelines. Effect: SLFRF requirements for pass-through entities were not followed. Questioned Costs: None. Context/Sampling: Sampling was not utilized. The County issued one subaward during the period under audit. Recommendation: The County should create a subrecipient monitoring policy and include evidence of compliance with the policy in the subrecipient monitoring file. Views of Responsible Officials: Management agrees with the noted finding. Refer to Corrective Action Plan. Repeat Finding from Prior Year: No
2022-001: Considered a significant deficiency in internal control over compliance/immaterial non-compliance Program: ALN 93.958 Block Grants for Prevention and Treatment of Substance Abuse (Treatment and Access Management) 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.
Criteria: According to ? 200.303 Internal controls of Title 2 U.S. Code of Federal Regulations (CFR) Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to ? 200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must: ? Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. ? 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. ? 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. ? Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Condition: During our testing, it was noted that the City did not follow federal subrecipient monitoring regarding evaluating the subrecipients risk of noncompliance and performing monitoring activities which includes on-site reviews and audits, follow-up audits, review of financial and performance reports, and keeping written documentation of monitoring activities and written corrective action plans. The risk assessment of subrecipients? risk of noncompliance was done informally and without written documentation. The City did not perform any monitoring activities and management regulation on subrecipients. Auditing procedures were expanded to included testing subrecipients for allowed and unallowed activities; allowable cost and cost principles; period of performance; and procurement, suspension, and debarment. During our testing, we noted that for one subrecipient tested, documentation supporting the expenditure was missing for 3 of 63 transactions tested. Cause: The City lacks policies and procedures regarding preforming monitoring activities on subrecipients. Effect: Lack of policies and procedures did not ensure that the subrecipients of the Coronavirus State and Local Fiscal Recovery Funds were properly monitored.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.