SPECIAL TESTS AND PROVISIONS ? OVERSIGHT AND MONITORING RESPONSIBILITIES WITH RESPECT TO CHARTER SCHOOLS WITH RELATIONSHIPS WITH CHARTER MANAGEMENT ORGANIZATIONS RIDE does not have any specific procedures to assess the risk posed by conflicts of interest, related party transactions or insufficient segregation of duties between the Charter School and Charter Management Organization (CMO). Criteria: As grantees, SEAs/LEAs are responsible for overseeing and monitoring subrecipients, including charter schools with relationships with Charter Management Organizations (CMOs). The SEA/LEA must: (1) evaluate each subrecipient?s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining appropriate subrecipient monitoring (2 CFR section 200.332(b)); and (2) 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 section 200.332(d)). Charter schools with relationships with CMOs that receive federal grant funds must comply with statutes authorizing the applicable grant program, regulations, the terms and conditions of their grant awards, and relevant department-issued guidance. Additionally, under Title 2 of the Code of Federal Regulations Part 200 ? Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Grant Guidance), nonfederal entities that receive federal grants: (1) must establish and maintain effective internal controls over those funds and (2) should have internal controls that comply with the US Government Accountability Office (GAO) ?Standards for Internal Control in the Federal Government? (Green Book), issued in November 1999 and updated in September 2014, or the ?Internal Control ? Integrated Framework,? issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO) in 1992 and updated in May 2013. The Green Book and the COSO Internal Control ? Integrated Framework (COSO framework) provide specific requirements for assessing and reporting on controls in the federal government. Additional requirements applicable to nonfederal entities receiving federal funds include: (1) the Code of Federal Regulations (CFR) requirements regarding conflicts of interest, (2) guidance regarding related-party transactions in generally accepted accounting principles, and (3) the GAO Green Book and COSO framework guidance regarding segregation of duties applicable to charter schools with relationships with CMOs. Condition: RIDE?s policies, procedures, and internal control for reviewing charter schools with relationships with Charter Management Organizations (CMOs) is the same for all Local Education Agencies (LEA). Those policies and procedures do not include any specific procedures to assess the risk posed by conflicts of interest, related party transactions or insufficient segregation of duties between the Charter School and CMO. Cause: RIDE currently has one Charter School with a relationship with a CMO and they did not modify their policies, procedures, and internal controls to address the Federal requirements related to the relationship. Effect: RIDE is not in compliance with federal regulations. Questioned Costs: None Valid Statistical Sampling: Not Applicable RECOMMENDATIONS 2022-055 Enhance the policies, procedures, and internal controls over monitoring LEAs, Charter Schools, and Charter Schools with relationships to CMOs to include assessing the risk posed by conflicts of interest, related-party transactions or insufficient segregation of duties between the Charter School and CMO.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
SUBRECIPIENT MONITORING The State has not implemented adequate subrecipient monitoring activities to ensure material compliance with federal regulations for several federal programs. Background: The State currently relies on the specific grantee agencies to ensure compliance with federal regulations for subrecipient monitoring, when applicable to the underlying federal programs. There is no statewide monitoring to ensure that activities are performed to ensure compliance with federal regulations. Criteria: 2 CFR 200.332(d) ?Requirements for pass-through entities?, requires that all pass-through entities must ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.? That monitoring must include (1) reviewing financial and performance reports, (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.? Condition: For the federal programs cited above, State pass-through agencies did not perform subrecipient monitoring activities required by federal regulations. Our testing evaluated whether the grantee agency obtained and reviewed the subrecipient?s Single Audit, when applicable, or performed other required monitoring activities to comply with federal regulations. For these programs, the following results, specific to agency reviews of financial and performance reports, were deemed to be material noncompliance with subrecipient monitoring requirements: [See Schedule of Findings and Questioned Costs for tables.] For subrecipients that were not required to have Single Audits performed, agencies also did not perform required monitoring procedures, which could have included monitoring the subrecipient?s use of federal awards through reporting, site visits, regular contact, or other means to provide reasonable assurance that the subrecipient administers federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements. Cause: The State did not conduct subrecipient monitoring activities required to materially comply with federal regulations. Effect: Noncompliance with federal compliance requirements by subrecipients could occur without the State identifying it in a timely manner. Questioned Costs: None Valid Statistical Sampling: Yes RECOMMENDATION 2022-039 Improve policies and procedures statewide to ensure compliance with federal regulations for subrecipient monitoring.
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department for the Aging (?DFTA?) Finding #: 2022-016 Funding Year(s): 07/01/2021 - 06/30/2022 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(a)(1) stipulate that pass-through entities include specific Federal award information within sub-award contracts. Such information, among other things, should include: i. Subrecipient?s unique identifying number; ii. Federal Award Identification Number; iii. Federal Award Date of award to City Agency by the Federal agency; iv. Name of Federal awarding agency; and v. Assistance Listing title Condition/Context: Of the forty (40) subrecipient contracts under the Aging Cluster that were selected for testing, none of the contracts included any of the data points described above (i.-v.) in accordance with 2 CFR 200.332(a)(1). Cause/Effect: While DFTA has established subrecipient monitoring procedures, such procedures did not adequately contemplate all of the required elements and/or data points necessary to be included in all of their respective subrecipient agreements. Missing or incomplete required data elements could result in subrecipients not having sufficient information to appropriately comply with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is similar to finding #2021-005 included on pages 236 through 237 of the of the Fiscal 2021 Single Audit report. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including a review of all subrecipient contracts and related amendments, to ensure every subrecipient agreement contains all of the required information stipulated by 2 CFR 200.332(a)(1).
New York City Department of Health and Mental Hygiene (?DOHMH?) Finding #: 2022-005 Funding Year(s): 8/1/2020 - 12/31/2022 HIV Prevention Activities ? Health Department Based (FAL #93.940) Contract Numbers: 5 NU62PS924575-04-00; 5 NU62PS924575-05-00; 1NU62PS924626-01-00; 6NU62PS924626-02-01 Federal Agency: U.S. Department of Health and Human Services Type of Finding: Subrecipient Monitoring - Compliance and Internal Control (Significant Deficiency) Criteria: The subrecipient monitoring requirements of 2 CFR 200.332(d) stipulate that pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition/Context: During fiscal 2022, DOHMH passed through federal funding to one subrecipient. We selected this subrecipient for testing and noted that DOHMH did not perform any of the required monitoring procedures in accordance with 2 CFR 200.332(d). Cause/Effect: While DOHMH has established procedures to comply with certain aspects of the subrecipient monitoring compliance requirements, such procedures did not include performing on-site reviews or similar alternate procedures that would allow DOHMH to properly oversee and evaluate the subrecipients? compliance with the requirements of the subaward. Without proper monitoring procedures, DOHMH may not have the appropriate amount of information to ensure the subrecipient is being used in accordance with Federal guidelines and the terms of the subaward. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DOHMH create a comprehensive internal control structure which ensures that all subrecipient compliance requirements are being met, including performing appropriate monitoring procedures to ensure each subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals of the subaward.
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-042) Title: Internal control over CACFP subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child and Adult Care Food Program (CACFP) Assistance Listing Number: 10.558 Federal Award Identification Number: 214ME301N1099, 214ME301N1199, 224ME301N1199, 214ME320N1150, 214ME325N2020, 224ME320N1150, 224ME325N2020, 214ME202H1706, 204ME320N1050 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Child and Adult Care Food Program (CACFP) provides nutritious foods that contribute to wellness, healthy growth, and development of eligible children and adults receiving care in day-care centers, day-care homes, and at-risk after school snack programs. Child Nutrition Services (CNS) is responsible for monitoring 104 subrecipients that administer these services. Those monitoring procedures include verifying that subrecipients that expend over $750,000 obtain a Single Audit in accordance with Federal regulations. CACFP was previously administered by the State Department of Health and Human Services (DHHS) and subrecipient audits were tracked, received, and reviewed by DHHS? Division of Audit. Prior to fiscal year 2022, the administration of CACFP was moved to the Department of Education (DOE). DOE School Finance and Operations is responsible for the tracking, receipt, and review of subrecipient audits for most programs administered by DOE. CNS asserted that subrecipient audits for private non-profit institutions were received and forwarded to DOE School Finance and Operations for review; however, DOE only stored the audits. Neither CNS nor DOE could provide documentation to support that tracking of subrecipient audit reports was maintained or that reports were received and reviewed. As a result, 19 private non-profit subrecipients that reported receiving over $750,000 in Federal funds and required audits were not reviewed. Context: In fiscal year 2022, $9.3 million in CACFP funds was provided to 104 subrecipients, 51 of which are private non-profit subrecipients and 19 were required to have an audit. Cause: ? Lack of policies and procedures. CNS and DOE School Finance and Operations have not defined roles and responsibilities for tracking, receiving, and reviewing subrecipient audit reports. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that CNS and DOE School Finance and Operations collaborate on implementing policies and procedures that define the roles and responsibilities for tracking, receipt, and review of subrecipient audits. Corrective Action Plan: See F-17 Management?s Response: The Department agrees with this finding. Child Nutrition will implement policies and procedures for the tracking, receipt, and review of audits for subrecipients that expend over $750,000, in accordance with Federal regulations. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1115-04)
(2022-044) Title: Internal control over CACFP subrecipient risk evaluation procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child and Adult Care Food Program (CACFP) Assistance Listing Number: 10.558 Federal Award Identification Number: 214ME301N1099, 214ME301N1199, 224ME301N1199, 214ME320N1150, 214ME325N2020, 224ME320N1150, 224ME325N2020, 214ME202H1706, 204ME320N1050 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures. Condition: The Child and Adult Care Food Program (CACFP) provides nutritious foods that contribute to wellness, healthy growth, and development of eligible children and adults receiving care in day-care centers, day-care homes, and at-risk after school snack programs. The Department is responsible for monitoring 104 subrecipients that administer these services. The level of monitoring required by Federal regulations must be determined using a risk-based approach. Subrecipient risk evaluation should include considerations of: ? the subrecipient?s experience with the program, ? the results of subrecipient audits, ? changes in personnel or systems, and ? the extent of Federal awarding agency monitoring procedures. CACFP regulations require the Department to monitor 33.3 percent of total active facilities in each review cycle (annually). In addition, all facilities must be monitored at least once every three years and Sponsoring Organizations (SOs) with 100 or more facilities must be monitored once every two years. SOs provide administration and support for smaller facilities. Department subrecipient monitoring procedures are based on CACFP regulations and do not use the risk-based approach as required by Federal regulations. Context: In fiscal year 2022, CACFP expenditures totaled $9.4 million, of which $9.3 million was provided to 104 subrecipients. Cause: Lack of adequate policies and procedures Effect: ? Noncompliance with Federal regulations ? Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. Recommendation: We recommend that the Department review and update policies and procedures to incorporate Federal regulations along with program regulations. The risk evaluation process should be documented and retained. Corrective Action Plan: See F-17 Management?s Response: The Department agrees with this finding. The CACFP team will create a risk assessment tool to use in scheduling subrecipient reviews. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1115-03)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-035) Title: Internal control over CNC subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Child Nutrition Services Federal Agency: U.S. Department of Agriculture Assistance Listing Title: Child Nutrition Cluster (COVID-19) Assistance Listing Number: 10.553, 10.555, 10.556, 10.559, 10.582 Federal Award Identification Number: 214ME300L1603, 214ME301N1099, 214ME301N1199, 224ME301N1199, 224ME300L1603, 214ME102H1703, 224ME902N8903 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: The Department of Education (DOE) School Finance and Operations is responsible for tracking and reviewing subrecipient audits on behalf of the Child Nutrition Cluster (CNC). CNC program subrecipients include schools that are provided Federal funds to support food service programs. The Office of the State Auditor (OSA) requested a list of subrecipients that required audits in fiscal year 2022 from DOE to test compliance with Federal regulations. OSA independently queried the State?s accounting system to develop a separate list for comparison and to ensure completeness. OSA compared DOE?s tracking to OSA?s generated list and found two subrecipients that were excluded from DOE?s tracking. DOE?s tracking excluded two private schools that received Federal funds in excess of the $750,000 Single Audit requirement; therefore, the audits for the two schools were not received or reviewed. Context: In fiscal year 2022, $113 million was provided to 254 subrecipients. Approximately 120 subrecipients were required to have an audit in accordance with Federal regulations. Cause: ? Lack of adequate policies and procedures. DOE policies do not provide guidance over tracking audits of private schools. ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department implement policies and procedures to ensure that audit reports for all subrecipients, including private schools, receiving over $750,000 in Federal awards are tracked, received, and reviewed. Corrective Action Plan: See F-15 Management?s Response: The Department agrees with this finding. Child Nutrition will create policies and procedures to collect, track, and review single audits for private schools receiving over $750,000 in Federal awards. Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880 (State Number: 22-1203-04)
(2022-049) Title: Internal control over ERA Program subrecipient monitoring needs improvement Prior Year Findings: None State Department: Economic and Community Development State Bureau: Commissioner?s Office Federal Agency: U.S. Department of the Treasury Assistance Listing Title: Emergency Rental Assistance Program (COVID-19) Assistance Listing Number: 21.023 Federal Award Identification Number: ERA0299, ERA0434, ERAE0515, ERAE0563 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must monitor the activities of the subrecipient as necessary to ensure that subawards are 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. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited as required. Condition: In fiscal year 2022, the Department passed through Emergency Rental Assistance (ERA) Program funds to one subrecipient. Subrecipient monitoring procedures included providing Federal award information in grant award agreements and frequent communication with the subrecipient; however, the Department: ? did not adequately design and document ongoing monitoring activities to ensure that the subaward was used for authorized purposes and in compliance with Federal regulations. ? could not provide a documented review of the subrecipient?s audit report to verify compliance with Subpart F of 2 CFR 200 and to ensure that the subrecipient took timely and appropriate action on all deficiencies pertaining to the Department?s subaward. The Office of the State Auditor reviewed the subrecipient?s audit report covering a portion of fiscal year 2022 and noted findings related to the subaward that should have been considered in relation to the risk of subrecipient noncompliance and planned monitoring procedures. ? did not require submission of detailed expenditure information with the subrecipient?s requests for reimbursement of ERA Program funds. A summary spreadsheet outlining actual and projected expenditures for second-tier subrecipients was the only support provided to the Department with each reimbursement request. Context: The Department provided $245.8 million to the ERA subrecipient during fiscal year 2022. Cause: ? Lack of supervisory oversight ? Lack of adequate policies and procedures Effect: ? Noncompliance with Federal regulations ? Lack of ongoing subrecipient monitoring procedures could result in subrecipient noncompliance. Recommendation: We recommend that the Department develop and implement additional policies and procedures to require: ? ongoing subrecipient monitoring during the use of the subaward; ? receipt and documented review of subrecipient audits in order to consider the effects of audit results on subrecipient risk assessment and planned monitoring procedures; and ? receipt of detailed documentation in support of subrecipient reimbursement requests prior to payment approval. Corrective Action Plan: See F-19 Management?s Response: The Department agrees with this finding. Due to the Emergency Rental Assistance Program coming to a close, the Department plans on utilizing a consultant to assist with close out procedures that will ensure these subrecipient funds were used for authorized purposes and in compliance with Federal regulations. Additionally, the Department will ensure that the review of subrecipient audit reports are sufficiently documented. Contact: Deborah Johnson, Director, Office of Community Development, DECD, 207-624-9817 (State Number: 22-1695-02)
(2022-057) Title: Internal control over ESF subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Federal Agency: U.S. Department of Education Assistance Listing Title: Education Stabilization Fund (ESF) (COVID-19) Assistance Listing Number: 84.425D, 84.425R, 84.425U Federal Award Identification Number: S425C200004, S425C210004, S425D200004, S425D210004, S425U210004, S425W210020, S425R210044, S425B200039 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.313; 2 CFR 200.332 The Department must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Department is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. For equipment acquired with Federal funding, records must be maintained that include: ? a description and identification number; ? the source of funding, including the Federal Award Identification Number; ? who holds title and the acquisition date; ? the cost of the property, including the percentage of Federal participation in the project costs for the Federal award under which the property was acquired; ? the location, use and condition; and ? any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Education Stabilization Fund (ESF) provides funding to school administrative units (SAUs) to purchase equipment for use in preventing, preparing for, or responding to the COVID-19 pandemic. SAUs were required to submit applications to the Office of Federal Emergency Relief Programs (OFERP) under the Department of Education outlining identified uses for ESF including planned equipment purchases. Program coordinators within OFERP were responsible for reviewing and approving applications submitted by SAUs. Once there was an approved application on file, SAUs could submit reimbursement requests to the Department for equipment purchases identified and approved in the application. All SAU equipment purchases reimbursed with ESF are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Federal regulations for equipment and real property management. During fiscal year 2022, the Department did not have policies and procedures in place to track SAU equipment purchases reimbursed with ESF; therefore, the Department does not have assurance that: ? a complete and accurate record of all equipment purchased with ESF funds was maintained by each SAU. ? proper monitoring activities surrounding subrecipient compliance with Federal regulations for equipment and real property management were conducted. Context: In fiscal year 2022, ESF expenditures totaled $126.4 million, of which $120.6 million was paid to subrecipient SAUs. Cause: ? Lack of policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be in compliance with equipment and real property management requirements. ? Assets purchased with ESF funds may not be properly safeguarded or maintained. Recommendation: We recommend that the Department implement policies and procedures to ensure that a complete and accurate record of all equipment purchased under ESF is maintained by the Department and by each SAU. This record should be utilized during subrecipient monitoring activities to verify subrecipient compliance with Federal regulations. Corrective Action Plan: See F-21 Management?s Response: The Department agrees with this finding. The Office of Federal Emergency Relief Programs will develop and implement policies and procedures so that complete and accurate records of all equipment purchased under ESF will be maintained by each SAU and the Department when collected during subrecipient monitoring. Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180 (State Number: 22-1235-06)
(2022-057) Title: Internal control over ESF subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Federal Agency: U.S. Department of Education Assistance Listing Title: Education Stabilization Fund (ESF) (COVID-19) Assistance Listing Number: 84.425D, 84.425R, 84.425U Federal Award Identification Number: S425C200004, S425C210004, S425D200004, S425D210004, S425U210004, S425W210020, S425R210044, S425B200039 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.313; 2 CFR 200.332 The Department must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Department is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. For equipment acquired with Federal funding, records must be maintained that include: ? a description and identification number; ? the source of funding, including the Federal Award Identification Number; ? who holds title and the acquisition date; ? the cost of the property, including the percentage of Federal participation in the project costs for the Federal award under which the property was acquired; ? the location, use and condition; and ? any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Education Stabilization Fund (ESF) provides funding to school administrative units (SAUs) to purchase equipment for use in preventing, preparing for, or responding to the COVID-19 pandemic. SAUs were required to submit applications to the Office of Federal Emergency Relief Programs (OFERP) under the Department of Education outlining identified uses for ESF including planned equipment purchases. Program coordinators within OFERP were responsible for reviewing and approving applications submitted by SAUs. Once there was an approved application on file, SAUs could submit reimbursement requests to the Department for equipment purchases identified and approved in the application. All SAU equipment purchases reimbursed with ESF are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Federal regulations for equipment and real property management. During fiscal year 2022, the Department did not have policies and procedures in place to track SAU equipment purchases reimbursed with ESF; therefore, the Department does not have assurance that: ? a complete and accurate record of all equipment purchased with ESF funds was maintained by each SAU. ? proper monitoring activities surrounding subrecipient compliance with Federal regulations for equipment and real property management were conducted. Context: In fiscal year 2022, ESF expenditures totaled $126.4 million, of which $120.6 million was paid to subrecipient SAUs. Cause: ? Lack of policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be in compliance with equipment and real property management requirements. ? Assets purchased with ESF funds may not be properly safeguarded or maintained. Recommendation: We recommend that the Department implement policies and procedures to ensure that a complete and accurate record of all equipment purchased under ESF is maintained by the Department and by each SAU. This record should be utilized during subrecipient monitoring activities to verify subrecipient compliance with Federal regulations. Corrective Action Plan: See F-21 Management?s Response: The Department agrees with this finding. The Office of Federal Emergency Relief Programs will develop and implement policies and procedures so that complete and accurate records of all equipment purchased under ESF will be maintained by each SAU and the Department when collected during subrecipient monitoring. Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180 (State Number: 22-1235-06)
(2022-057) Title: Internal control over ESF subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner?s Office Federal Agency: U.S. Department of Education Assistance Listing Title: Education Stabilization Fund (ESF) (COVID-19) Assistance Listing Number: 84.425D, 84.425R, 84.425U Federal Award Identification Number: S425C200004, S425C210004, S425D200004, S425D210004, S425U210004, S425W210020, S425R210044, S425B200039 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.313; 2 CFR 200.332 The Department must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the Department is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. For equipment acquired with Federal funding, records must be maintained that include: ? a description and identification number; ? the source of funding, including the Federal Award Identification Number; ? who holds title and the acquisition date; ? the cost of the property, including the percentage of Federal participation in the project costs for the Federal award under which the property was acquired; ? the location, use and condition; and ? any ultimate disposition data including the date of disposal and sale price of the property. A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. The Department must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition: The Education Stabilization Fund (ESF) provides funding to school administrative units (SAUs) to purchase equipment for use in preventing, preparing for, or responding to the COVID-19 pandemic. SAUs were required to submit applications to the Office of Federal Emergency Relief Programs (OFERP) under the Department of Education outlining identified uses for ESF including planned equipment purchases. Program coordinators within OFERP were responsible for reviewing and approving applications submitted by SAUs. Once there was an approved application on file, SAUs could submit reimbursement requests to the Department for equipment purchases identified and approved in the application. All SAU equipment purchases reimbursed with ESF are subject to applicable inventory control, log maintenance, and disposition requirements consistent with Federal regulations for equipment and real property management. During fiscal year 2022, the Department did not have policies and procedures in place to track SAU equipment purchases reimbursed with ESF; therefore, the Department does not have assurance that: ? a complete and accurate record of all equipment purchased with ESF funds was maintained by each SAU. ? proper monitoring activities surrounding subrecipient compliance with Federal regulations for equipment and real property management were conducted. Context: In fiscal year 2022, ESF expenditures totaled $126.4 million, of which $120.6 million was paid to subrecipient SAUs. Cause: ? Lack of policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Subrecipients may not be in compliance with equipment and real property management requirements. ? Assets purchased with ESF funds may not be properly safeguarded or maintained. Recommendation: We recommend that the Department implement policies and procedures to ensure that a complete and accurate record of all equipment purchased under ESF is maintained by the Department and by each SAU. This record should be utilized during subrecipient monitoring activities to verify subrecipient compliance with Federal regulations. Corrective Action Plan: See F-21 Management?s Response: The Department agrees with this finding. The Office of Federal Emergency Relief Programs will develop and implement policies and procedures so that complete and accurate records of all equipment purchased under ESF will be maintained by each SAU and the Department when collected during subrecipient monitoring. Contact: Shelly Chasse-Johndro, Director of OFERP, DOE, 207-458-3180 (State Number: 22-1235-06)
(2022-058) Title: Internal control over ICA program subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Health and Human Services State Bureau: Maine Center for Disease Control & Prevention Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.268 Federal Award Identification Number: NH23IP922604 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must: ? include Federal award information in the subaward that enables subrecipients to identify the source of the Federal award, as well as certain subrecipient information. ? evaluate each subrecipient?s risk of noncompliance with Federal regulations for the purposes of determining the appropriate level of subrecipient monitoring to be performed. ? monitor the activities of the subrecipient as necessary to ensure that subawards are 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. Condition: The Department is responsible for ensuring subrecipients comply with Federal requirements by: ? reviewing subrecipient grant awards to ensure accurate Federal award identification information is included to allow subrecipients to accurately identify the source of the subawards; ? utilizing risk evaluations to determine the appropriate level of monitoring activities to be performed that correspond to the results of those risk evaluations; and ? performing ongoing monitoring activities to ensure that the subaward was used for authorized purposes and in compliance with Federal regulations. The Office of the State Auditor (OSA) tested compliance with subrecipient monitoring requirements for 7 subrecipients and found that: ? 3 subawards did not properly identify required Federal award information: o 2 subawards were missing the subrecipient?s Data Universal Numbering System (DUNS) number. o 2 subawards reported the wrong Assistance Listing Number. ? 2 subrecipients were deemed ?higher risk? after the Department performed a risk evaluation; however, the Department could not provide documentation to support that additional monitoring activities were performed in response to the ?higher risk? designation. ? 80 performance reports were required to be completed and submitted for fiscal year 2022 to ensure subaward performance goals are achieved. o 47 reports were provided to the auditor but lacked evidence of supervisory review. o 33 reports could not be provided. ? 52 financial reports were required to be completed and submitted for fiscal year 2022 to ensure subawards are used for approved budgeted expenditures. o 32 reports were provided to the auditor but lacked evidence of supervisory review. o 20 reports could not be provided. The Department could not provide any further documentation to support subrecipient monitoring procedures occurred during fiscal year 2022 to ensure that the subaward was used for authorized purposes. OSA selected a non-statistical random sample. Context: The Department provided $2.5 million to 35 Immunization Cooperative Agreements (ICA) program subrecipients in fiscal year 2022. Cause: ? Lack of adequate policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Lack of ongoing subrecipient monitoring procedures could result in undetected subrecipient noncompliance. Recommendation: We recommend that the Department implement policies and procedures to ensure that: ? subaward agreements include all required information and are accurate; ? risk evaluations are utilized to determine the appropriate level of monitoring activities to be performed; and ? ongoing subrecipient monitoring is completed during the subaward and documented. This will ensure that the Department is in compliance with subrecipient monitoring requirements. Corrective Action Plan: See F-22 Management?s Response: The Department agrees with this finding. The Department initiated these subrecipient agreements to ensure equitable access to COVID-19 vaccines. As a result of these agreements, Maine had one of the best vaccine roll-outs in the country, including among Black, Indigenous, and People of Color. Some of the information requested by OSA was unable to be accessed because it was saved in individual staff files which were moved when an employee was transferred or left employment with the Department. The Department will implement processes in SFY23 to improve record keeping for these subawards including: 1) reviewing subaward agreements using a checklist to ensure they include all the required information and are accurate; 2) ensuring that risk evaluations are utilized to determine the appropriate level of monitoring; and 3) improving and centralizing subrecipient monitoring documentation within the Office of Population Health Equity (OPHE) at Maine CDC. Contact: Ian Yaffe, Director, Office of Population Health Equity, DHHS, 207- 592-1481 (State Number: 22-1118-03)
(2022-058) Title: Internal control over ICA program subrecipient monitoring procedures needs improvement Prior Year Findings: None State Department: Health and Human Services State Bureau: Maine Center for Disease Control & Prevention Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Immunization Cooperative Agreements (COVID-19) Assistance Listing Number: 93.268 Federal Award Identification Number: NH23IP922604 Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must: ? include Federal award information in the subaward that enables subrecipients to identify the source of the Federal award, as well as certain subrecipient information. ? evaluate each subrecipient?s risk of noncompliance with Federal regulations for the purposes of determining the appropriate level of subrecipient monitoring to be performed. ? monitor the activities of the subrecipient as necessary to ensure that subawards are 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. Condition: The Department is responsible for ensuring subrecipients comply with Federal requirements by: ? reviewing subrecipient grant awards to ensure accurate Federal award identification information is included to allow subrecipients to accurately identify the source of the subawards; ? utilizing risk evaluations to determine the appropriate level of monitoring activities to be performed that correspond to the results of those risk evaluations; and ? performing ongoing monitoring activities to ensure that the subaward was used for authorized purposes and in compliance with Federal regulations. The Office of the State Auditor (OSA) tested compliance with subrecipient monitoring requirements for 7 subrecipients and found that: ? 3 subawards did not properly identify required Federal award information: o 2 subawards were missing the subrecipient?s Data Universal Numbering System (DUNS) number. o 2 subawards reported the wrong Assistance Listing Number. ? 2 subrecipients were deemed ?higher risk? after the Department performed a risk evaluation; however, the Department could not provide documentation to support that additional monitoring activities were performed in response to the ?higher risk? designation. ? 80 performance reports were required to be completed and submitted for fiscal year 2022 to ensure subaward performance goals are achieved. o 47 reports were provided to the auditor but lacked evidence of supervisory review. o 33 reports could not be provided. ? 52 financial reports were required to be completed and submitted for fiscal year 2022 to ensure subawards are used for approved budgeted expenditures. o 32 reports were provided to the auditor but lacked evidence of supervisory review. o 20 reports could not be provided. The Department could not provide any further documentation to support subrecipient monitoring procedures occurred during fiscal year 2022 to ensure that the subaward was used for authorized purposes. OSA selected a non-statistical random sample. Context: The Department provided $2.5 million to 35 Immunization Cooperative Agreements (ICA) program subrecipients in fiscal year 2022. Cause: ? Lack of adequate policies and procedures ? Lack of supervisory oversight Effect: ? Noncompliance with Federal regulations ? Lack of ongoing subrecipient monitoring procedures could result in undetected subrecipient noncompliance. Recommendation: We recommend that the Department implement policies and procedures to ensure that: ? subaward agreements include all required information and are accurate; ? risk evaluations are utilized to determine the appropriate level of monitoring activities to be performed; and ? ongoing subrecipient monitoring is completed during the subaward and documented. This will ensure that the Department is in compliance with subrecipient monitoring requirements. Corrective Action Plan: See F-22 Management?s Response: The Department agrees with this finding. The Department initiated these subrecipient agreements to ensure equitable access to COVID-19 vaccines. As a result of these agreements, Maine had one of the best vaccine roll-outs in the country, including among Black, Indigenous, and People of Color. Some of the information requested by OSA was unable to be accessed because it was saved in individual staff files which were moved when an employee was transferred or left employment with the Department. The Department will implement processes in SFY23 to improve record keeping for these subawards including: 1) reviewing subaward agreements using a checklist to ensure they include all the required information and are accurate; 2) ensuring that risk evaluations are utilized to determine the appropriate level of monitoring; and 3) improving and centralizing subrecipient monitoring documentation within the Office of Population Health Equity (OPHE) at Maine CDC. Contact: Ian Yaffe, Director, Office of Population Health Equity, DHHS, 207- 592-1481 (State Number: 22-1118-03)
(2022-071) Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Office for Family Independence Office of Child and Family Services Division of Contract Management Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in 2 CFR 200.332. Condition: The Department has established subrecipient monitoring procedures depending on whether the subaward is competitively bid or not. If a subaward is competitively bid, the Department seeks input from the Department of Health and Human Services Service Center, and the Department?s Division of Audit and Division of Contract Management regarding known issues with the provider who submitted the bid. Those responses are collected and provided to the evaluation team which consists of various program personnel. The subaward agreement is then drafted and the level of subrecipient monitoring is included in the agreement. If a subaward is not competitively bid, the subaward agreement is drafted based on the level of subrecipient monitoring that the Department has established for the provided services. The Office of the State Auditor (OSA) selected seven TANF subrecipients for testing and found: ? one subrecipient competitively bid on the subaward. The Department was able to provide evidence to support that feedback was solicited from other Bureaus for any known issues or prior noncompliance; however, documentary evidence could not be provided to support the level of subrecipient monitoring that was completed. ? six subrecipients did not competitively bid on the subaward. For those six subrecipients, no documentary evidence could be provided to support the level of subrecipient monitoring that was completed. OSA selected a non-statistical random sample. Context: The Department provided $17.9 million to TANF subrecipients during fiscal year 2022. Cause: Lack of adequate policies and procedures Effect: ? Without a documented process, subrecipient risk evaluation procedures may not be consistently followed, and documentation may not be adequately maintained. ? Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. Recommendation: We recommend that the Department: ? document procedures that outline the collaborative process with all Bureaus. ? implement policies and procedures that require evaluation of each subrecipient?s risk of noncompliance specifically for the purposes of determining the appropriate subrecipient monitoring to be performed. This will ensure subrecipients are monitored appropriately based on risk designation. Corrective Action Plan: See F-26 Management?s Response: The Department disagrees with this finding. The Department has subrecipient monitoring procedures for all of its subrecipients whether they were competitively bid or not. The first assessment of risk, as noted in the finding, is when a subaward is competitively bid. Secondly, another risk assessment built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP) in which requires higher risk subrecipients to undergo a higher level of testing. Additionally, there are audit and review requirements at a much lower threshold than that of the Uniform Guidance (UG). Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. The Department?s subrecipient monitoring procedures ensures that we comply with the UG 200.332(d) Pass-through entity (PTE) monitoring of the subrecipient must include: 1) Review of financial and performance reports. 2) Following-up and ensuring that subrecipients take timely and appropriate action on all deficiencies. 3) Issues management decisions. 4) PTE is responsible for resolving audit findings specifically related to the subaward. Based on the Department?s MAAP rules we ensure we comply with UG 200.332(e). Depending on the PTE?s assessment of risk, the following tools may be useful: 1) Training and technical assistance. 2) On-site reviews. 3) Arranging for agreed upon procedures. The Department covers #3 by ensuring that all of our subrecipients have a requirement to submit to the Department a/an Audit, Review or Schedule of Expenditures of Department Awards (SEDA). Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The Department has misinterpreted the Federal regulation cited in this finding. The Department has responded to 2 CFR 200.332(d), which identifies monitoring procedures to be conducted during the subrecipient award period. OSA audited compliance with this during-the-award monitoring requirement and did not identify deficiencies. The Federal regulation that the Department failed to meet is 2 CFR 200.332(b). This regulation identifies procedures to be performed prior to monitoring procedures in order to determine the level of monitoring required for each subrecipient. 2 CFR 200.332(b) states that the Department 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, which may include consideration of factors such as: ? the subrecipient?s prior experience with the same or similar subawards; ? the results of previous audits including whether or not the subrecipient receives a Single Audit, and the extent to which the same or similar subaward has been audited as a major program; ? whether the subrecipient has new personnel or new or substantially changed systems; and ? the extent and results of Federal awarding agency monitoring. The Department did not provide any documentation to support that monitoring procedures performed were based on an evaluation of the subrecipient?s risk of noncompliance. The finding remains as stated. (State Number: 22-1111-05)
(2022-076) Title: Internal control over TANF subrecipient audit procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited. Condition: The Department requires subrecipients to submit their Single Audit to the Department?s Division of Audit. The Division maintains a database to track when subrecipient Single Audit reports are due and ensures that they are received. The Office of the State Auditor (OSA) tested four TANF subrecipients that had a Single Audit due in fiscal year 2022 for compliance with Federal regulations and found that the Division did not obtain the Single Audit for one subrecipient. The Division could not provide documentation to support that they contacted the subrecipient when the Single Audit was late. OSA was able to confirm that the subrecipient did have a Single Audit as required. Context: A Single Audit was due in fiscal year 2022 for eight TANF subrecipients that received $28.2 million of Federal funds in fiscal year 2021. Cause: ? Lack of adequate procedures ? Lack of supervisory oversight Effect: Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance existing procedures to ensure that subrecipients that expend $750,000 or more in Federal awards complete and submit a Single Audit within the required time requirements. Corrective Action Plan: See F-27 Management?s Response: The Department agrees with this finding. We will revise our standard operating procedures (SOP) to include the search for out of state subrecipients on the Federal Audit Clearinghouse. Contact: Herb Downs, Director, Division of Audit, DHHS, 207-287-2778 (State Number: 22-1100-02)
(2022-071) Title: Internal control over TANF subrecipient risk evaluation procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Office for Family Independence Office of Child and Family Services Division of Contract Management Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Material weakness Material noncompliance Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department is required to evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in 2 CFR 200.332. Condition: The Department has established subrecipient monitoring procedures depending on whether the subaward is competitively bid or not. If a subaward is competitively bid, the Department seeks input from the Department of Health and Human Services Service Center, and the Department?s Division of Audit and Division of Contract Management regarding known issues with the provider who submitted the bid. Those responses are collected and provided to the evaluation team which consists of various program personnel. The subaward agreement is then drafted and the level of subrecipient monitoring is included in the agreement. If a subaward is not competitively bid, the subaward agreement is drafted based on the level of subrecipient monitoring that the Department has established for the provided services. The Office of the State Auditor (OSA) selected seven TANF subrecipients for testing and found: ? one subrecipient competitively bid on the subaward. The Department was able to provide evidence to support that feedback was solicited from other Bureaus for any known issues or prior noncompliance; however, documentary evidence could not be provided to support the level of subrecipient monitoring that was completed. ? six subrecipients did not competitively bid on the subaward. For those six subrecipients, no documentary evidence could be provided to support the level of subrecipient monitoring that was completed. OSA selected a non-statistical random sample. Context: The Department provided $17.9 million to TANF subrecipients during fiscal year 2022. Cause: Lack of adequate policies and procedures Effect: ? Without a documented process, subrecipient risk evaluation procedures may not be consistently followed, and documentation may not be adequately maintained. ? Subrecipients that are deemed higher risk may not be monitored on a more frequent basis. Conversely, subrecipients that are deemed lower risk may not be monitored on a less frequent basis, which would free resources and time to dedicate towards other higher risk subrecipients. Recommendation: We recommend that the Department: ? document procedures that outline the collaborative process with all Bureaus. ? implement policies and procedures that require evaluation of each subrecipient?s risk of noncompliance specifically for the purposes of determining the appropriate subrecipient monitoring to be performed. This will ensure subrecipients are monitored appropriately based on risk designation. Corrective Action Plan: See F-26 Management?s Response: The Department disagrees with this finding. The Department has subrecipient monitoring procedures for all of its subrecipients whether they were competitively bid or not. The first assessment of risk, as noted in the finding, is when a subaward is competitively bid. Secondly, another risk assessment built into the Maine Uniform Accounting and Auditing Practices for Community Agencies (MAAP) in which requires higher risk subrecipients to undergo a higher level of testing. Additionally, there are audit and review requirements at a much lower threshold than that of the Uniform Guidance (UG). Finally, the Social Service Unit of the Division of Audit performs a risk assessment and tests transactions for those subrecipients that have been determined to be higher risk. The Department?s subrecipient monitoring procedures ensures that we comply with the UG 200.332(d) Pass-through entity (PTE) monitoring of the subrecipient must include: 1) Review of financial and performance reports. 2) Following-up and ensuring that subrecipients take timely and appropriate action on all deficiencies. 3) Issues management decisions. 4) PTE is responsible for resolving audit findings specifically related to the subaward. Based on the Department?s MAAP rules we ensure we comply with UG 200.332(e). Depending on the PTE?s assessment of risk, the following tools may be useful: 1) Training and technical assistance. 2) On-site reviews. 3) Arranging for agreed upon procedures. The Department covers #3 by ensuring that all of our subrecipients have a requirement to submit to the Department a/an Audit, Review or Schedule of Expenditures of Department Awards (SEDA). Contact: Jim Lopatosky, Director, Division of Contract Management, DHHS, 207-287-5075 Auditor?s Concluding Remarks: The Department has misinterpreted the Federal regulation cited in this finding. The Department has responded to 2 CFR 200.332(d), which identifies monitoring procedures to be conducted during the subrecipient award period. OSA audited compliance with this during-the-award monitoring requirement and did not identify deficiencies. The Federal regulation that the Department failed to meet is 2 CFR 200.332(b). This regulation identifies procedures to be performed prior to monitoring procedures in order to determine the level of monitoring required for each subrecipient. 2 CFR 200.332(b) states that the Department 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, which may include consideration of factors such as: ? the subrecipient?s prior experience with the same or similar subawards; ? the results of previous audits including whether or not the subrecipient receives a Single Audit, and the extent to which the same or similar subaward has been audited as a major program; ? whether the subrecipient has new personnel or new or substantially changed systems; and ? the extent and results of Federal awarding agency monitoring. The Department did not provide any documentation to support that monitoring procedures performed were based on an evaluation of the subrecipient?s risk of noncompliance. The finding remains as stated. (State Number: 22-1111-05)
(2022-076) Title: Internal control over TANF subrecipient audit procedures needs improvement Prior Year Findings: See Schedule of Findings and Questioned Costs for chart/table State Department: Health and Human Services State Bureau: Division of Audit Federal Agency: U.S. Department of Health and Human Services Assistance Listing Title: Temporary Assistance for Needy Families (TANF) (COVID-19) Assistance Listing Number: 93.558 Federal Award Identification Number: 1901METANF, 2001METANF, 2101METANF Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. When a subrecipient?s Federal award expenditures are expected to equal or exceed $750,000 during the fiscal year, the Department must verify that the subrecipient is audited. Condition: The Department requires subrecipients to submit their Single Audit to the Department?s Division of Audit. The Division maintains a database to track when subrecipient Single Audit reports are due and ensures that they are received. The Office of the State Auditor (OSA) tested four TANF subrecipients that had a Single Audit due in fiscal year 2022 for compliance with Federal regulations and found that the Division did not obtain the Single Audit for one subrecipient. The Division could not provide documentation to support that they contacted the subrecipient when the Single Audit was late. OSA was able to confirm that the subrecipient did have a Single Audit as required. Context: A Single Audit was due in fiscal year 2022 for eight TANF subrecipients that received $28.2 million of Federal funds in fiscal year 2021. Cause: ? Lack of adequate procedures ? Lack of supervisory oversight Effect: Noncompliance with Federal regulations Recommendation: We recommend that the Department enhance existing procedures to ensure that subrecipients that expend $750,000 or more in Federal awards complete and submit a Single Audit within the required time requirements. Corrective Action Plan: See F-27 Management?s Response: The Department agrees with this finding. We will revise our standard operating procedures (SOP) to include the search for out of state subrecipients on the Federal Audit Clearinghouse. Contact: Herb Downs, Director, Division of Audit, DHHS, 207-287-2778 (State Number: 22-1100-02)
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), all pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and 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. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), all pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and 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. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), all pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and 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. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name - 14.241, U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) Federal Award Identification Number and Year - N/A Pass-through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - No Criteria - Per 2 CFR 200.332(b) and (d), all pass-through entities must evaluate each subrecipient's risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring and 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. Condition - The City did not perform a risk assessment of the subrecipient during the year and did not maintain documentation of subrecipient monitoring as evidence to support subrecipient monitoring performed. Questioned Costs - Unknown Identification of How Questioned Costs Were Computed - N/A Context - The City has a policy in place that it must perform an annual risk assessment of each subrecipient and guidelines for how to perform subrecipient monitoring. The City has one subrecipient that received HOPWA funding, and the City did not perform the required annual risk assessments for this subrecipient. Cause and Effect - The City did not have adequate controls to ensure its policies related to subrecipient monitoring were followed, resulting in inadequate monitoring of subrecipients. Recommendation - The City should ensure that policies on internal controls and processes adequately address the requirements and are complied with. Views of Responsible Officials and Corrective Action Plan - The City agrees with the finding and will put procedures in place to ensure appropriate documentation is retained related to subrecipient monitoring and comply with the relevant internal policies.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.
Assistance Listing Number, Federal Agency, and Program Name 21.027, U.S. Department of Treasury, Coronavirus State and Local Fiscal Recovery Fund 97.024, Department of Homeland Security, Emergency Food and Shelter National Board Program 97.036, Federal Emergency Management Agency, Disaster Grants Public Assistance (Presidentially Declared Disasters) Federal Award Identification Number and Year N/A Pass through Entity 21.027 Kendall County and Lake County 97.024 United Way of Boone County, Kishwaukee United Way (DeKalb County), United Way of Metropolitan Chicago (DuPage County), Fox Valley United Way (Kane County), Kankakee County Committee Service, Inc., Kendall County Health Department, United Way of Lake County, McHenry County Community Development, HOPE of Ogle County, United Way of Will County, United Way of Rock River Valley (Winnebago County) 97.036 Illinois Department of Human Services/Feeding Illinois Finding Type Significant deficiency Repeat Finding No Criteria Per 2 CFR 200.332(d), pass-through entities are 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 the subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include, among other things, 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 and highlighting the status of actions planned or taken to address single audit findings related to the particular subwaward. Condition It was noted through testing that there were multiple agencies where a monitoring visit had not taken place within the last two years per the Food Bank's subrecipient monitoring policy. Questioned Costs N/A Identification of How Questioned Costs Were Computed N/A Context Of the 77 monitoring visits tested, 9 had not had a monitoring visit by the Food Bank within the two prior years. Cause and Effect Due to COVID-19 protocols limiting on-site contact, site monitoring visits were delayed and not completed in a timely manner. If monitoring visits are not properly performed or follow-up is not completed, there is a risk that the food being passed to the participants is not sanitary or safe. Recommendation We recommend that the Food Bank ensure monitoring visits are completed consistently with the policy in place and that all issues identified are followed up on and completed as quickly as possible. Views of Responsible Officials and Corrective Action Plan The director, compliance manager, and three area leaders of the agency team maintain a schedule of sites to be monitored. During the pandemic, there were extensive site closings and reduced hours, which impeded the ability to maintain the schedule. In order to maintain a safe work environment, it was necessary to reduce visits during peak periods of the pandemic. This was a unique and short-term issue. Each team member has a goal of conducting weekly monitoring visits in order to complete the overdue visits by June 30, 2023. Monitoring visits will be prioritized from oldest to newest until the schedule is brought current. Area leaders will continue conducting site monitoring visits with agencies prior to their upcoming due dates.