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.
2022-007-Subrecipient Monitoring Federal Agency: U.S. Department of the Treasury Federal Program Name: Covid-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number: Z1890 Award Period: March 3, 2021, through December 31, 2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 2 CFR section 200.332(a) notes pass-through entities such as Polk County, Florida need to ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required information at the time of the subaward sufficient for the subrecipient to comply with federal statutes, regulation, and the terms and conditions of the award. If any of the data elements change the impact should be updated in subsequent subaward modification. 2 CFR section 200.332(b)-(f) covers required monitoring activities and management of subrecipient relationships that should be performed by the pass-through entity. Condition: During the testing of quarterly Project and Expenditure Reports submitted to the Treasury, information included for contracts and subawards was not agreeing to information reported on the Schedule of Expenditures of Federal Awards (SEFA). Auditors selected reported subrecipients, beneficiaries, and contractors to determine the validity of assigned category. A subrecipient is an entity that receives a subaward to carry out a project funded by Fiscal Recovery Funds on behalf of a recipient. Individuals or entities that are direct beneficiaries of a project funded by Fiscal Recovery Funds are not considered subrecipients. Households, communities, small businesses, nonprofits, and impacted industries are all potential beneficiaries of projects carried out with SLFRF funds. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. Beneficiaries are not subject to the requirements placed on subrecipients in the Uniform Guidance. The distinction between a subrecipient and a beneficiary, therefore, is contingent upon the rationale for why a recipient is providing funds to the individual or entity. If the recipient is providing funds to the individual or entity for the purpose of carrying out a SLFRF program or project on behalf of the recipient, the individual or entity is acting as a subrecipient. Acting as a subrecipient, the individual or entity is subject to subrecipient monitoring and reporting requirements. Questioned costs: N/A Context: A statistically valid sample of 10 organizations listed on each of the quarterly Treasury reports (40 total items tested) was selected and tested against the entity-type determination criteria. In the sample of 40 entity types reported, there were twenty-three exceptions (23) which resulted in a conclusion that only one (1) Organization reported was truly a subrecipient. This subrecipient was not captured on the SEFA and the elements of monitoring were not in place. The review of the contract agreement between Polk County and this subrecipient did not meet all requirements under 2 CFR section 200.332(a). Cause: The distinction between the entity types receiving this federal funding was not fully understood by personnel. Effect: Recipients and subrecipients are the first line of defense and responsible for ensuring the SLFRF award funds are not used for ineligible purposes, and there is no fraud, waste, or abuse associated with their SLFRF award. The terms and conditions of Federal awards flow down to subawards to subrecipients, requiring subrecipients to comply with all requirements of recipients such as the treatment of eligible uses of funds, procurement, and reporting requirements. A lack of monitoring can lead to noncompliance by the subrecipient which ultimately impacts the compliance of the pass-through entity. Repeat Finding: No. Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Views of responsible officials: There is no disagreement with the audit finding.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Criteria: The requirements for subrecipient monitoring for subawards are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h); federal awarding agency regulations; and the terms and conditions of awards. Condition: Monitoring activities performed by the County did not encompass certain areas necessary to ensure that the subaward complied with the terms and conditions of the subaward and achieved performance goals (2 CFR sections 200.332(d) through (f). Specifically, no onsite reviews of 2022 program year operations were conducted during the year. Cause/Effect: The County did not have adequate procedures in place for monitoring that subrecipients were complying with federal regulations and had achieved performance goals. Auditor's Recommendation: The County should review the monitoring plan related to the program to ensure these procedures are done timely and meet the federal requirements for monitoring subrecipients.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501.” Condition: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Compliance Requirement Subrecipient monitoring Material Weakness Material Noncompliance 2022-003. The County should establish controls to ensure subrecipients are sufficiently monitored. Assistance Listing Number 21.027 Federal Award Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of the Treasury Pass-through N/A – Direct Award Questioned Costs None Context There was one transaction passed-through to a subrecipient. Repeat Finding No Criteria The Federal Compliance Supplement and 2 CFR Section 200.332 requires pass-through entities to communicate and clearly identify to the subrecipient: 1) the award as a subaward at the time of the subaward by providing the information described in 2 CFR section 200.332(a)(1); 2) all requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and terms and conditions of the award; and 3) any additional requirements the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. It also requires the pass-through entity to verify that every subrecipient is audited under the Uniform Guidance when required. Condition The County did not have an effective process in place to ensure required communications occurred with subrecipients of federal awards. There was no agreement with the subrecipient that explicitly included certain information required under 2 CFR 200.332(a)(1). During our audit of the County’s federal expenditures, we noted that the only procedure in place to monitor the subrecipient’s use of federal awards was a visual inspection of the work completed. Cause Management was not aware of the additional communication requirements imposed on pass-through entities. Effect Failure to monitor subrecipient’s use of federal awards could result in the erroneous or fraudulent spending of federal awards, as well as a risk the subrecipient may not be audited in accordance with the Uniform Guidance when required. Recommendation We recommend the County update its communications with the subrecipient to include the required communications of the subrecipient’s responsibilities under the federal requirements, grant agreements and award requirements including, but not limited to its audit obligations under the Uniform Guidance. Views of Responsible Official(s) This payment was a one-time payment for a single project completed by the City of Meridian. Moving forward, Lauderdale County will document the completion of the project.
Finding Number: 2022-041 Prior Year Finding Number: 2021-036 Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of Treasury COVID-19 - Coronavirus Relief Fund ALN: 21.019 Award #: N/A Award Period: 03/01/2020 – 12/31/2021 Government Department/Agency: Office of Management and Budget (OMB) Criteria – A pass-through entity (PTE) must: Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: 1. The award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); 2. All requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); 3. Any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 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 PTE detected through audits, on-site reviews, and other means. 3. 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. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We reviewed two sub-awards made during 2022 and found that OMB did not evaluate the risks or monitor the two subrecipients. Further, it does not appear that the controls in place are operating at a level of precision to ensure compliance with the subrecipient monitoring compliance requirements. Questioned Costs – None. Context – This is a condition identified per review of OMB’s compliance with the specified requirements and general compliance principles. The total amount of expenditures passed through to subrecipients in fiscal year 2022 were $4,500,000. Effect – OMB is not in compliance with the stated provisions. Failure to properly monitor subrecipients can result in noncompliance with laws and regulations and failure to meet the programs objectives. Cause – OMB does not have internal controls in place to properly monitor subrecipients to ensure adherence to applicable federal regulations, including expending federal awards for allowable expenditures. Recommendation – We recommend that OMB implement policies, procedures, and controls to ensure subrecipients are monitored in accordance with federal statutes. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. OMB will establish a robust framework featuring detailed monitoring procedures, regular compliance checks, and comprehensive oversight mechanisms to ensure subrecipients adhere to federal requirements. This framework aims to promote accountability, proper use of federal funds, mitigate risks, enhance transparency, and ensure subrecipients effectively fulfill their obligations under federal statutes. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-045 Prior Year Finding Number: N/A Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Period: 03/03/2021 – 12/31/2024 Government Department/Agency: Office of Management and Budget (OMB) Criteria – A pass-through entity (PTE) must: Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: 1. The award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); 2. All requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); 3. Any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 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 PTE detected through audits, on-site reviews, and other means. 3. 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. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We obtained a list of subrecipients from OMB and found that the list identified internal Government of the Virgin Islands (GVI) departments and offices as subrecipients. The list of subrecipients also included an external entity whose federal expenditures are part of the GVI Schedule of Expenditures of Federal Awards. As a result, the listing of subrecipients was amended to exclude 23 projects totaling $23,559,959. Using the amended listing of subrecipients, we selected 12 of 18 subrecipients and found the following: • 3 projects which OMB did not verify if the entity underwent a single audit as required by 2 CFR part 200, subpart F. • 1 project which OMB did not complete their monitoring workbook during the fiscal year • 5 projects in which there was no evidence the monitoring workbook was reviewed by the ARPA Grants Administrator. • 6 projects where entities were identified as subrecipients but were ultimately considered to be beneficiaries of SLFRF funds and not subrecipients. Further, it does not appear that the controls in place are operating at a level of precision to ensure compliance with the subrecipient monitoring compliance requirements or proper identification of subrecipients. Questioned Costs – None. Context – This is a condition identified per review of OMB’s compliance with the specified requirements using a statistically valid sample. The total amount of expenditures passed through to subrecipients in fiscal year 2022 were $56,490,165. The total amount of our sample totaled $46,452,928. Effect – OMB is not in compliance with the stated provisions. Failure to properly identify and monitor subrecipients can result in noncompliance with laws and regulations and failure to meet the programs objectives. Cause – OMB does not have internal controls in place to properly identify and monitor subrecipients to ensure adherence to applicable federal regulations, including expending federal awards for allowable expenditures. Recommendation – We recommend that OMB implement policies, procedures, and controls to ensure subrecipients are identified and monitored in accordance with federal statutes. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. Starting FY25, OMB will identify and monitor federal awarding agencies, requesting single audit results for applicable recipients and including them in monitoring reviews. For revenue replacement projects, Treasury's Final Rule FAQ (13.14) states that these funds do not create subrecipient relationships, thus exempting them from the Single Audit Act due to the absence of a federal program or purpose. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number 2022-051 Prior Year Finding Number: N/A Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of Education Consolidated Grant to the Outlying Areas, ALN: 84.403A Award #: Various Award Period: Various Government Department/Agency: Department of Education (VIDE) Criteria – Per Compliance Supplement, a pass-through entity (PTE) must: • Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). • Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). • Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 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 PTE detected through audits, on-site reviews, and other means. 3. 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. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We sampled subawards to 3 out of 10 subrecipients and found no supporting documentation that VIDE verified that subrecipients expected to be audited as required by 2 CFR part 200, subpart F. Additionally, there was no evidence of award monitoring performed for 2 of the 3 subrecipients tested. Further, it does not appear that the controls in place are operating at a level of precision to ensure compliance with the subrecipient monitoring compliance requirements. Questioned Costs – None. Context – This is a condition identified per review of VIDE’s compliance with the specified requirements and general compliance principles. The total amount of expenditures passed through to subrecipients in fiscal year 2022 were $1,051,727. Effect – VIDE is not in compliance with the stated provisions. Failure to properly monitor subrecipients can result in noncompliance with laws and regulations and failure to meet the programs objectives. Cause – VIDE does not have internal controls in place to properly monitor subrecipients to ensure adherence to applicable federal regulations, including expending federal awards for allowable expenditures. Recommendation – We recommend that VIDE implement policies, procedures, and controls to ensure subrecipients are monitored in accordance with federal statutes. Views of Responsible Officials - The Government concurs with the auditor’s findings and recommendations. VIDE is committed to strengthening controls to ensure subrecipient compliance with federal audit requirements under 2 CFR Part 200, Subpart F. This includes implementing effective measures, such as explicit reporting requirements in subrecipient agreements and providing training to internal staff on subrecipient monitoring requirements and ensure consistent implementation. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding Number: 2022-082 Prior Year Finding Number: N/A Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of Homeland Security Disaster Grants - Public Assistance (Presidentially Declared Disasters) ALN: 97.036 Award #: FEMA-4335-DR, FEMA-4340-DR-VI, FEMA-4513-DR Award Periods: 09/20/2017 – 09/07/2026 09/07/2017 – 09/16/2025 04/02/2020 – 05/11/2023 Government Department/Agency: Virgin Islands Territorial Emergency Management Agency (VITEMA) Criteria – A pass-through entity (PTE) must: Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: 1. The award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); 2. All requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); 3. Any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: 1. The subrecipient’s prior experience with the same or similar subawards; 2. The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 3. Whether the subrecipient has new personnel or new or substantially changed systems; and 4. The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the PTE. 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 PTE detected through audits, on-site reviews, and other means. 3. 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. Further, the Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition – We selected 8 of 25 subrecipients and found the following: • 5 instances where we were unable to obtain subrecipient agreements. • 8 instances where we were unable to obtain Quarterly Progress Reports. • 3 instances with no Certification Letter of Completion of Work and Disaster Response and Recovery Final Inspection Report. • 8 instances with no supporting documentation that VITEMA verified that subrecipients expected to be audited as required by 2 CFR part 200, subpart F. Further, it does not appear that the controls in place are operating at a level of precision to ensure compliance with the subrecipient monitoring compliance requirements or proper identification of subrecipients. Questioned Costs – None. Context – This is a condition identified per review of VITEMA’s compliance with the specified requirements using a statistically valid sample. The total amount of expenditures passed through to subrecipients in fiscal year 2022 were $205,714,063. The total amount of our sample totaled $190,927,885. Effect – VITEMA is not in compliance with the stated provisions. Failure to properly identify and monitor subrecipients can result in noncompliance with laws and regulations and failure to meet the programs objectives. Cause – VITEMA does not have internal controls in place to properly identify and monitor subrecipients to ensure adherence to applicable federal regulations, including expending federal awards for allowable expenditures. Recommendation – We recommend that VITEMA implement policies, procedures, and controls to ensure subrecipients are identified and monitored in accordance with federal statutes. Views of Responsible Officials – The Government concurs with the auditor’s findings and recommendations. The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the Recipient, the Territory is responsible for notifying the Subrecipient when federal funds are obligated and providing them with a subrecipient agreement outlining the program's terms and conditions. The Disaster Program Financial Specialist is responsible for ensuring that the subrecipient agreement is signed by both the Applicant and the Governor's Authorized Representative and provided to the Territorial Public Assistance Officer. The planned corrective actions are presented in the Government’s Corrective Action Plan attached as Appendix B to the Single Audit Report.
Finding No.: 2022-005 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D22AF00029-00 Area: Subrecipient Monitoring Questioned Costs: $1,030,566 Criteria: In accordance with applicable subrecipient requirements (CFR §200.332), a pass-through entity (PTE) must: a. Ensure that the subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the PTE must provide the best information available to describe the Federal award and subaward. Required information includes: 1. Federal award identification: (i) Subrecipient’s name, (ii) Subrecipient’s unique entity identifier, (iii) Federal Award Identification Number (FAIN), (iv) Federal Award Date, (v) Subaward Period of Performance Start and End Date, (vi) Subaward Budget Period Start and End Date, (vii) Amount of Federal Funds Obligated by this action by the PTE to the subrecipient, (viii) Total Amount of Federal Funds Obligated to the subrecipient by the PTE including the current financial obligation, (ix) Total Amount of the Federal Award committed to the subrecipient by the PTE, (ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA), (x) Name of Federal awarding agency, PTE, and contact information for awarding official of the PTE, and (xi) Assistance Listings Number and Title; the PTE must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement. 2. All requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. b. 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, c. Verify that every subrecipient is audited as required by CFR Subpart F when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR § 200.501, d. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the PTE's own records, and e. Consider taking enforcement action against noncompliant subrecipients as described in CFR §200.339. Condition: An amount of $1,030,566 (Doc #626) was passed through to Belau Submarine Cable Corporation (BSCC), a component unit of the Republic, for the submarine fiber optic cable project for the year ended September 30, 2022; however, there was lack of evidence to indicate that the above criteria was met. Cause: The Republic lacks internal control policies and procedures to identify subrecipient relationships and monitor subrecipients to ensure compliance with applicable subrecipient requirements. Effect: The Republic is in noncompliance with applicable subrecipient requirements and therefore $1,030,566 is questioned. Recommendation: The Republic should develop and implement internal control policy and procedures to identify subrecipient relationship and monitor activities of subrecipients to ensure compliance with applicable subrecipient requirements. Views of Responsible Officials: The Republic’s Corrective Action Plan does not indicate disagreement and provides planned corrective action.
Finding No. 2022-019 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D17AP00016, D18AP00016, D19AP00081 D21AP10043, D21AP000138, D19AP00090 Area: Subrecipient Monitoring Questioned Costs: $549,849 Criteria: 1. In accordance with 2 CFR § 200.332, pass-through entity (PTE) must: a. Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. b. Verify that a subrecipient is audited as required by subpart F. 2. In accordance with 2 CFR §200.1, a subrecipient is defined as an entity that receives a subaward from a PTE to carry out part of a Federal award. The term subrecipient does not include a beneficiary or participant. A subrecipient may also be a recipient of other Federal awards directly from a Federal agency. 3. Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a PTE should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). Condition: Of nine subrecipients tested, aggregating $1,263,952 of a total population of $2,022,623, the following were noted: 1. For nine (or 100%), documentation of the risk assessments performed and verification as to whether the subrecipients are not suspended or debarred were not provided. No questioned costs for grant awards with no corresponding FY2022 expenditures. Of eight subrecipient monitoring procedure requirements tested, the following were noted: 2. For two (or 25%), the subrecipients’ performance reports did not include the required project narrative report that entails the current state or progress completion in accordance with the scope of work. 3. For eight (or 100%), no verification as to whether the subrecipients are subject to the audit requirements were provided. No questioned costs are presented as amounts are questioned at Condition 1 for grant award numbers D18AP00026, D21AP00138 and D21AP10043 while the other grant awards have no corresponding FY2022 expenditures. Cause: The CNMI does not have written subrecipient monitoring policies and procedures. In addition, the CNMI failed to enforce compliance with subrecipient monitoring requirements and lacks monitoring controls over the following: 1. Monitoring activities of a subrecipient to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward; 2. Adequate documentation and systematic filing of relevant documentation supporting program costs. Effect: CNMI is in noncompliance with the applicable subrecipient monitoring requirements and questioned costs of $549,849 result for Condition 1. Identification as a Repeat Finding: Finding No. 2021-022 Recommendation: We recommend the CNMI establish an approved/adopted written subrecipient monitoring policies and procedures and implement monitoring internal control procedures over the following: 1. Verification that subrecipients are not excluded or disqualified in accordance with § 180.300, which includes confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving federal funds; 2. Verification that subrecipients are audited as required by subpart F; 3. Monitoring activities of a subrecipient to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward; 4. Adequate documentation and systematic filing of relevant documentations to support program costs. Views of Responsible Officials: Condition 1 - CIP agrees with this finding. To address this finding, CIP will implement a standardized risk assessment checklist to be used for all subrecipients to confirm they are not suspended, debarred, or excluded under 2 CFR §180.300; all staff responsible for subrecipient monitoring will receive training on federal requirements for exclusion checks and proper documentation procedures; and conduct periodic reviews to ensure that SAM.gov checks are consistently performed and documented for all new and existing subrecipients. Condition 2 - CIP disagrees with this finding. The subrecipient was not required to submit the required project narrative report; instead, the report was prepared and submitted by the project manager responsible for managing the project as assigned by CIP. Condition 3 - We acknowledge the finding that documentation was not provided to verify whether eight subrecipients were subject to the audit requirements. CIP will strengthen its subrecipient monitoring procedures to ensure compliance with 2 CFR 200.331(f) and related audit requirements. Refer to CNMI’s Corrective Action Plan for additional information. Auditor Response: Condition 2 - As stated in the subaward agreements, subrecipients shall furnish to the CNMI, project documents certifying beneficiary occupancy and/or substantial completion. This is done through submission of a project narrative status report to the CNMI, which includes information such as scope of work, percentage of completion, status of the project and anticipated completion date. As subrecipients are required to submit certification of project status, report should be prepared by the subrecipients and should be consistently required for all subawards.
Finding No. 2022-027 Federal Agency: U.S. Department of the Treasury AL Program: 21.026 Homeowner Assistance Fund Program Federal Award No.: HAF0205 Area: Subrecipient Monitoring Questioned Costs: $4,157,924 Criteria: In accordance with 2 CFR § 200.332, a pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient: 1) The award as a subaward at the time of subaward by providing the information described in 2 CFR § 200.332(a)(1); 2) All requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award; and 3) Any additional requirements that the PTE imposes in order for the PTE to meet its own responsibility for the federal award. • Evaluating the impact of subrecipient activities on the PTE’s ability to comply with applicable federal regulations. Condition: 1. We are unable to obtain an understanding of the CNMI’s process to identify subawards, evaluate risk of noncompliance, and perform monitoring procedures based upon identified risks. 2. The CNMI did not provide a subrecipient agreement. Instead, a memorandum of agreement (MOA) was issued between the CNMI and the subrecipient for reimbursement of costs in the planning and administration of the program. The MOA did not have the following required information: • Subrecipient’s unique entity identifier; • Federal Award Identification Number (FAIN); • Federal award Date of award to the recipient by the Federal agency; • Subaward Period of Performance Start and End Date; • Subaward Budget Period Start and End Date; • Amount of Federal Funds Obligated by this action by CNMI; • Total Amount of Federal Funds Obligated to the subrecipient; • Total amount of the Federal award committed to the subrecipient by CNMI; • Federal award project description, as required to be responsive to the Federal Funding and Transparency Act (FFATA); • Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the CNMI; • Identification of whether the award is R&D; and • Indirect cost rate for the Federal award (including if the de minimis rate is charged) 3. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipient. Total FY2022 subrecipient expenditures amounted to $4,157,924, for which the amount is questioned. 4. There was no evidence of procedures used to monitor the subrecipient’s compliance with applicable laws, regulations, and provisions of contracts and grant agreements. Further, we are aware that the subrecipient is subjected to Single Audits; however, there was no evidence that the Single Audit report was used as a monitoring tool. Cause: 1. CNMI has no existing written subrecipient monitoring policies and procedures; and 2. CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $4,157,924 result for Condition 3. Recommendation: The CNMI should establish written policies and procedures over compliance with applicable subrecipient monitoring requirements and consider obtaining training in the area of subrecipient monitoring. Views of Responsible Officials: Conditions 1 to 4 - The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. Refer to CNMI’s Corrective Action Plan for additional information.
Finding No. 2022-031 Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $61,003,095 Criteria: Per the U.S. Treasury Interim and Final Rules, the U.S. Treasury is aligning the definition of subrecipient in the final rule with the definition of subrecipient in the Uniform Guidance, wherein, subrecipients are entities that receive a subaward from a recipient to carry out a program or project on behalf of the recipient with the recipient’s Federal award funding but does not include an individual that is a beneficiary of such award. The recipient remains responsible for monitoring and overseeing the subrecipient’s use of Fiscal Recovery Funds and other activities related to the award to ensure that the subrecipient complies with the statutory and regulatory requirements and the terms and conditions of the award. Recipients also remain responsible for reporting to Treasury on their subrecipients’ use of payments from the Fiscal Recovery Funds for the duration of the award. Accordingly, in accordance with 2 CFR § 200.332, pass-through entity (PTE) must: 1. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A PTE must provide the best available information when some of the information below is unavailable. A PTE must provide the unavailable information when it is obtained. One of the required information includes: (1) Federal award identification: (i) Subrecipient’s unique entity identifier; (ii) Federal Award Identification Number (FAIN); (iii) Subaward Period of Performance Start and End Date; (iv) Subaward Budget Period Start and End Date; (v) Amount of Federal Funds Obligated in the subaward; (vi) Total Amount of Federal Funds Obligated to the subrecipient by the PTE, including the current financial obligation; (vii) Total Amount of Federal Funds Obligated to the subrecipient by the PTE, including the current financial obligation; and (viii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement. (2) All requirements of the subaward, including requirements imposed by Federal statutes, regulations, and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient for the pass-through entity to meet its responsibilities under the Federal award. This includes information and certifications (see § 200.415) required for submitting financial and performance reports that the pass-through entity must provide to the Federal agency; (4) A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements; and (5) Appropriate terms and conditions concerning the closeout of the subaward. 2. Evaluate each subrecipient’s fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient’s risk, a PTE should consider the following: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). 3. Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The PTE is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a PTE must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the PTE as required by §200.521. (4) Resolve audit findings specifically related to the subaward. However, the PTE is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the PTE may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 4. Verify that a subrecipient is audited as required by subpart F. 5. Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. Further, in accordance with 31 CFR § 19.300, prior to entering into subawards with award funds, recipients must verify that such subrecipients are not suspended, debarred, or otherwise excluded from receiving federal funds. Condition: 1. Of seventeen subrecipients tested, aggregating $60,403,095 of a total population of $61,003,095, the following were noted: a. For seventeen (or 100%), documentations of the risk assessments performed and verification as to whether the subrecipients are not suspended or debarred were not provided. b. For two (or 12%), subrecipient agreements were not provided. No questioned costs are presented as amounts are questioned at Condition 1a. c. For two (or 12%), subrecipients’ unique entity identifiers, the federal award identification numbers (FAIN), amounts of federal funds obligated by this action by the PTE to the subrecipients, total amount of federal funds obligated to the subrecipients by the PTE, including the current financial obligations and the appropriate terms and conditions concerning the closeout of the subawards, were not included in the subrecipient agreements. No questioned costs are presented as amounts are questioned at Condition 1a. d. For ten (or 59%), subawards were supported with financial assistance request letters from the subrecipients and not with a subaward agreement that CNMI utilizes for other subawards. Accordingly, other than the date of request, amount requested and purpose of the financial assistance, all other required subaward information pursuant to 2 CFR § 200.332, were not indicated. No questioned costs as amounts are questioned at Condition 1a. e. For one (or 6%), no monitoring procedures were performed. No questioned cost is presented as the amount is questioned at Condition 1a. 2. Of sixteen subrecipient monitoring procedure requirements tested, aggregating $58,537,352 of a total population of $58,537,352, for sixteen (or 100%), documentation on monitoring procedures performed were not provided. In addition, documentation of preventive measures taken to mitigate risk from subrecipients that showed elevated risk factors or for identified unallowable activities were not documented and no verification as to whether the subrecipients are subject to the audit requirements. 3. Of sixty monitoring procedure requirements tested at the invoice/disbursement level, aggregating $58,438,922 of a total population of $61,003,095, the following were noted: a. For six (or 10%), review and approval of invoices and/or payments to ensure that subrecipients used the subaward for authorized purposes in compliance with Federal statutes, regulations, and the terms and conditions of the subawards, were not evident. No questioned costs are presented as expenditures pertain to subawards that were questioned at Condition 1a for Award Numbers CNMI22037 and COVID-19 Care Force Project. b. For twenty-four (or 40%), either the check payments and/or invoices or equivalent documentations were not provided; accordingly, the CNMI was not able to substantiate that monitoring procedures were performed to ensure that subrecipients used the subaward for authorized purposes in compliance with Federal statutes, regulations, and the terms and conditions of the subawards. No questioned costs are presented as expenditures pertain to subawards that were questioned at Condition 1a for Award Numbers NMPMG, CNMI 22037, CNMI22044 and COVID-19 Care Force Project and at Condition 2 for Award Reference Number 5302. Cause: The CNMI does not have approved/adopted written subrecipient monitoring policies and procedures. In addition, the CNMI failed to enforce compliance with subrecipient monitoring requirements and lacks monitoring controls over the following: 1. Monitoring activities of a subrecipient to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward; 2. Adequate documentation and systematic filing of relevant documentation supporting program costs. In addition, for award number CNMI22044, the Entity’s management has determined that it should be classified as a contractor under the agreement as the Entity’s role is to promote the program within the CNMI, develop a marketing and promotional campaign and disburse the award to the recipients identified by the CNMI. The Entity was not involved in reviewing and deciding which grant applicant is eligible to receive the grant. CNMI’s role in the review of grant applications and eligibility determination may have caused confusion as to whether the Entity that received the funds is a subrecipient or a contractor. As of the auditor’s report date, the CNMI and the Entity have yet to conclude whether the Entity received the funds in the role of a subrecipient or a contractor. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $61,003,095 for Condition 1. Identification as a Repeat Finding: Finding No. 2021-033 Recommendation: We recommend the CNMI establish approved/adopted written subrecipient monitoring policies and procedures and an approved template that includes all required clauses needed for subrecipient agreements. In addition, CNMI should implement monitoring internal control procedures over the following: 1. Preventive measures taken to mitigate risk from subrecipients that showed elevated risk factors or for identified unallowable activities are adequately documented. Recommendation, continued: 2. Verification that subrecipients are audited as required by subpart F; 3. Monitoring activities of a subrecipient to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward; 4. Provide subrecipients with training and technical assistance on program-related matters, including thorough explanation of their role as subrecipients; 5. Adequate documentation and systematic filing of relevant documentation to support program costs. Views of Responsible Officials: Conditions 1 to 3 - The Department of Finance agrees with this finding. The Department has recently adopted and approved (August 2025) a Subrecipient Monitoring Policy and Procedures which specifically focused on the implementation of 2 CFR 200.331. Refer to CNMI’s Corrective Action Plan for additional information.
Finding No. 2022-044 Federal Agency: U.S. Department of the Homeland Security AL Program: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Award No.: FEMA-4396-DR; FEMA-4234-DR, FEMA-4404-DR; FEMA-4511-DR Area: Subrecipient Monitoring Questioned Costs: $1,540,330 Criteria: In accordance with 2 CFR 200.332(e), a pass-through entity (PTE) must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The PTE is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a PTE must review financial and performance reports. Further, in accordance with 2 CFR 200.332(g), a PTE must verify that a subrecipient is audited as required by Subpart F when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Condition: 1. Of eight subrecipients tested, aggregating $1,540,330, of a total population of $6,850,955, the following were noted: a. For eight (or 100%), evidence of CNMI’s review of financial and programmatic reports were not provided. b. For two or (25%) subrecipients, the CNMI did not perform appropriate review and follow up of the subrecipients’ audited financial statements for fiscal year 2022, dated April 30, 2024 and February 23, 2024. The subrecipients’ SEFA failed to include the federal awards it received from the CNMI. No questioned costs are presented as the amounts are questioned at Condition 1a. 2. No evidence was provided of procedures used to determine that subrecipients expending $750,000 or more in Federal awards have met the audit requirement of 2 CFR part 200, subpart F and that the required audits are completed within nine months of the end of the subrecipient’s audit period. In addition, we are aware that Project Strings 8812210010, 8812210015, and FG88120004 Single Audit Reports were due; however, the audits are still ongoing. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $1,540,330 result for Condition 1a. Recommendation: The CNMI should consider developing a tracking system to monitor compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: Conditions 1 and 2 - The Public Assistance Office agrees with this finding and acknowledges that, as the pass-through entity, we are responsible for monitoring subrecipients. Refer to CNMI’s Corrective Action Plan for additional information.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements 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 Section 200.501 Audit requirements. (g) 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. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.