SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Ref. No. Compliance and Internal Control over Compliance Findings 2022-002 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of the Treasury Pass-Through Entity: State of Hawaii Executive Office of the Governor Program: ALN No. COVID-19 - 21.019 - Coronavirus Relief Fund Questioned Cost Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR ?200.332 - Requirements for pass-through entities requires that the County verify that every subrecipient is audited as required by the Uniform Guidance, when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded $750,000. Condition: During our testing of the subrecipient monitoring compliance requirement, we noted the County did not track and monitor its subrecipient to ensure that an audit was completed and submitted in accordance with the Uniform Guidance. Cause: The County did not follow its procedures to verify whether its subrecipient was audited as required by the Uniform Guidance. Effect: Failure to verify that subrecipients are audited as required by the Uniform Guidance could result in noncompliance with the authorized purpose and terms and conditions of the subaward. $ -- Identification as a Repeat Finding, if applicable See finding 2021-002 included in the Summary Schedule of Prior Audit Findings. Recommendation We recommend that the County follow its procedures to ensure that audits required by the Uniform Guidance are being performed when monitoring subrecipients. Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The State Treasurer's Office did not ensure all required information was provided to subrecipients of Coronavirus Relief Funds (CRF). In addition, the Office's internal controls were insufficient to ensure that subrecipients received communication regarding the necessary items. Required information not communicated included: ? Subrecipient's unique entity identifier, ? Federal award identification number, ? Federal award date, ? Subaward budget period start and end date, ? Total amount of Federal funds obligated to the subrecipient by the pass-through entity including the current financial obligation, ? Total amount of Federal award committed to the subrecipient by the pass-through entity, ? Name of awarding agency, ? Assistance listing number; and, ? Indirect cost rate for Federal award including if the de minimis rate is charged. CRITERIA Federal regulation, 2 CFR 200.332(a), requires pass-through entities to communicate specific required information to subrecipients. Federal regulation, 2 CFR 200.303, requires non-Federal entities, in part, to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The documents used to communicate award information to subrecipients did not contain all required items. EFFECT These required communications are intended to help subrecipients meet all their reporting requirements, and to meet all award terms. Subrecipients subject to Single Audits also need this information for their audits. CONTEXT The State Treasurer's Office was appropriated approximately $123.3 million of funds from the Coronavirus Relief Fund (CRF) to be distributed to local governments. Almost all the funding was allocated to cities and counties based on salary and benefit expenses for licensed law enforcement officers since Federal guidance allowed for CRF funding to be used to reimburse law enforcement payroll costs. The Director of the Office of Management and Budget sent out an email to the North Dakota Association of Counties and to the North Dakota League of Cities to be forwarded to city and county leaders that indicated such funding was available. A Certification Law Enforcement Payroll Reimbursement Form was attached to the email. The combined information provided in the body of the email and the certification form did not contain all required items. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Not a repeat finding. RECOMMENDATION We recommend the State Treasurer's Office: A) Communicate all required information of 2 CFR 200.332(a) to subrecipients. B) Develop procedures to ensure that all Coronavirus Relief Fund award information is communicated to subrecipients. OFFICE OF STATE TREASURER RESPONSE The Office of State Treasurer does agree with finding that we were not in compliance with Federal regulations related to providing required information to subrecipients of Coronavirus Relief Funds (CRF). See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
?See Schedule of Findings and Questioned Costs for chart/table? CONDITION The Department of Public Instruction did not make subrecipients aware of all required grant award information for the Child Nutrition Cluster program prior to February of 2021. CRITERIA 31 U.S.C. 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332 states the required information that pass-through entities must disclose. This includes information related to Federal award identification, requirements imposed by the pass-through entity on the subrecipient, any additional requirements, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states that non-Federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. CAUSE The prior audit finding corrective action wasn't implemented until February of 2021. Therefore, the grant templates were still missing information as was documented during the 2019-2020 single audit. EFFECT Subrecipients may not have been aware of all necessary grant information and requirements. CONTEXT During our audit period, there were 412 subrecipients receiving Federal grant agreements for the Child Nutrition Cluster program. During 2021, there were 215 subrecipients and 197 in 2022. As there was a similar finding in our prior audit that was not implemented until February of 2021, only grants obligated after this date and before the end of our audit period of 6/30/2022 were considered in our testing. Grants made prior to February 2021 were considered to have missing information. During our testing, no missing information was noted in grants made after February 2021. Where sampling was performed, the audit used a non-statistical sampling method. IDENTIFICATION AS A REPEAT FINDING Finding 2020-022 was reported in the immediate prior year. Finding 2018-042 and 2016-068 were made in previous years. The prior audit finding was reported as implemented on the summary schedule of prior audit findings. This materially misrepresents the status of the finding. RECOMMENDATION We recommend the Department of Public Instruction continue the corrective action that was implemented in February of 2021 to ensure subrecipients are made aware of all required grant award information for the Child Nutrition Cluster program. DEPARTMENT OF PUBLIC INSTRUCTION RESPONSE The Department of Public Instruction agrees with the recommendation See ?Management?s Response and Corrective Action? section of this report.
Reference Number: 2022-013 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: AA-36325-21-55-A-25 (4/1/2021 ? 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 ? 6/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Subrecipient Monitoring - Per 2 CFR section 200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1)(xii) Assistance Listing number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (Department) did not include all required information in a subaward agreement. Context: For one of six subawards selected for testing, the assistance listing number and federal award title was not included in the subaward agreement. Cause: The Department?s procedures and controls were not sufficient to ensure that subawards included all required information. Effect: Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Questioned costs: Undetermined. Recommendation: We recommend the Department review and enhance internal controls and procedures to ensure that all required information is included in its subawards. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-013 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: AA-36325-21-55-A-25 (4/1/2021 ? 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 ? 6/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Subrecipient Monitoring - Per 2 CFR section 200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1)(xii) Assistance Listing number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (Department) did not include all required information in a subaward agreement. Context: For one of six subawards selected for testing, the assistance listing number and federal award title was not included in the subaward agreement. Cause: The Department?s procedures and controls were not sufficient to ensure that subawards included all required information. Effect: Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Questioned costs: Undetermined. Recommendation: We recommend the Department review and enhance internal controls and procedures to ensure that all required information is included in its subawards. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-013 Prior Year Finding: 2021-016 Federal Agency: U.S. Department of Labor State Agency: Executive Office of Labor and Workforce Development Federal Program: WIOA Cluster Assistance Listing Number: 17.258, 17.259, 17.278 Award Number and Year: AA-36325-21-55-A-25 (4/1/2021 ? 6/30/2024), AA-34774-20-55-A-25 (4/1/2020 ? 6/30/2023) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: Subrecipient Monitoring - Per 2 CFR section 200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1)(xii) Assistance Listing number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing Number at time of disbursement. Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Executive Office of Labor and Workforce Development (Department) did not include all required information in a subaward agreement. Context: For one of six subawards selected for testing, the assistance listing number and federal award title was not included in the subaward agreement. Cause: The Department?s procedures and controls were not sufficient to ensure that subawards included all required information. Effect: Excluding required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Questioned costs: Undetermined. Recommendation: We recommend the Department review and enhance internal controls and procedures to ensure that all required information is included in its subawards. Views of responsible officials: Management agrees with the finding.
Finding Reference Number: SA2022-006 - Subrecipient Monitoring Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: EES4XJFTXC28 Criteria: 2 CFR sections 200.332(d) through (f) require that a pass-through entity identify the award and applicable requirements to each subrecipient, as well as evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward, and 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. As part of those requirements, Section 200.332(f) requires that the City as a pass through entity ?Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? In addition, section VI, Transfer, of the Interim Final Rule and section D, Transfer, of the Final Rule for the Coronavirus State and Local Fiscal Recovery Funds indicates that the recipient remains responsible for monitoring and overseeing the subrecipient?s use of Fiscal Recovery Funds and other activities related to the award to ensure that the subrecipient complies with the statutory and regulatory requirements and the terms and conditions of the award. Recipients also remain responsible for reporting to Treasury on their subrecipients? use of payments from the Fiscal Recovery Funds for the duration of the award. Condition: The City passed through grant funding of $1,000,000 to a nonprofit during fiscal year 2022 and although the City did perform monitoring procedures during the fiscal year, those procedures did not include seeing that the entity underwent a Single Audit. Since the City alone provided the nonprofit funding in excess of the $750,000 threshold, the City should have expected that a Single Audit was completed. Cause: We understand that City staff was not aware of the requirement to review the entity?s Single Audit. Effect: The City is not in compliance with the subrecipient monitoring requirements of 2 CFR section 200.332(f) or with section VI, Transfer, of the Interim Final Rule and section D, Transfer, of the Final Rule for the Coronavirus State and Local Fiscal Recovery Funds. Recommendation: The City should develop procedures to determine if subrecipients are subject to Single Audit each fiscal year, regardless of the level of funding provided by the City, and review the applicable Single Audit reports for the audit results. View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.
2022-002 STRIVING READERS COMPREHENSIVE LITERACY/COMPREHENSIVE LITERACY STATE DEVELOPMENT ? SUBRECIPIENT MONITORING ? NONCOMPLIANCE WITH SUBRECIPIENT GRANT AGREEMENT REQUIREMENTS ? ALN 84.371 ? MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE FINDING TYPE: Material Weakness - Material Noncompliance Finding 2022-002 Federal Program: Striving Readers Comprehensive Literacy/Comprehensive Literacy State Development ALN: 84.371 Federal Award Number(s) and Year(s): S371B100031, 2022 Federal Agency: U.S. Department of Education Pass Through Agency: North Dakota Department of Public Instruction Questioned Cost: $0 Condition Devils Lake Public School District did not prepare subrecipient grant agreements that included the elements as outlined in 2 CFR 200.332(a) for the Striving Readers Comprehensive Literacy/Comprehensive Literacy State Development programs. In addition, Devils Lake Public School District did not have procedures in place to ensure subrecipient grant agreements were prepared for all subrecipients and included all the required elements. Context Devils Lake Public School District provided funding to one subrecipient during the audit period. Payments to the subrecipient during fiscal year 2022 totaled $19,838. Where sampling was performed, the audit used a non-statistical sampling method. Effect Devils Lake Public School District may not have complied with all elements of 2 CFR 200.332(a). Therefore, subrecipients may not have been aware of all necessary grant information and requirements. Cause Devils Lake Public School District was not aware of the requirements set forth in 2 CFR 200.332(a) that needed to be included in the grant agreements and therefore did not implement procedures to ensure compliance. Criteria 31 U.S.C 7502(f)(2)(A) states that each pass-through entity shall provide subrecipient the Federal requirements which govern the use of such awards. 2 CFR 200.332(a) states the required information that pass-through entities must disclose. This includes information related to federal award identification and period of performance, approved federally recognized indirect cost rate, requirement that the subrecipient allow access to records, and appropriate terms and conditions concerning closeout of the subaward. 2 CFR 200.303(a) states: "The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." According to the ?Standards for Internal Control in the Federal Government?, Management develops and maintains documentation of its internal control system. Effective documentation assists in management?s design of internal control by establishing and communicating the who, what, when, where, and why of internal control execution to personnel. Documentation also provides a means to retain organizational knowledge and mitigate the risk of having that knowledge limited to a few personnel, as well as a means to communicate that knowledge as needed to external parties, such as external auditors. (Green Book, GAO-14-704G para 3.09 and 3.10). Questioned Costs None. Prior Recommendation No. Recommendation We recommend Devils Lake Public School District develop procedures to ensure that all elements as outlined in 2 CFR 200.332(a) are communicated and documented to the subrecipients of the Striving Readers Comprehensive Literacy/Comprehensive Literacy State Development programs. Devils Lake Public School District No. 1?s Response See Corrective Action Plan
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-111: Perform Subrecipient Monitoring Activities Required by the Risk Assessment Applicable to: Department of Housing and Community Development Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Material Weakness ALPT or Cluster Name and ALN: Emergency Rental Assistance Program - 21.023 (COVID-19) Federal Award Number and Year: ERA0402; ERAE070; ERA0451; ERAE0400 - 2022 Name of Federal Agency: U.S. Department of the Treasury Type of Compliance Requirement - Criteria: Eligibility - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Housing and Community Development has not monitored subrecipient activities for the ERA federal grant program in accordance with its subrecipient monitoring policies and procedures. Since the prior audit, Housing and Community Development performed a risk assessment for its ERA subrecipient and determined that they were high risk. Housing and Community Development's Risk Evaluation and Assessment Core Tool Instructions states that for a high risk subrecipient, program personnel must perform monitoring procedures as soon as possible but no later than six months after the completion of the risk assessment procedures, or a total of nine months from entering the subaward agreement. As of the end of the fiscal year, Housing and Community Development has not conducted the monitoring activities its Risk Evaluation and Assessment Core Tool Instructions requires. Over the life of the ERA federal grant program, the subrecipient has determined eligibility for landlords, which has led to beneficiary payment amounts totaling approximately $255 million. Title 2 CFR ? 200.332(d) requires grantees to monitor the activities of the subrecipient as necessary to ensure that it uses the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and that the subrecipient achieved subaward performance goals. While Housing and Community Development was able to demonstrate that it established recurring meetings to discuss the performance of the program with its subrecipient, these monitoring activities alone are not adequate based on the subrecipient's risk level identified in the risk assessment. In effect, Housing and Community Development cannot provide reasonable assurance that it used the subaward for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward. Reasonable assurance is a high, but not absolute, level of assurance that the entity and its subrecipient have complied with federal laws and regulations. Housing and Community Development was unable to perform the required monitoring activities because of the lack of time and available resources. Since management has not performed the required monitoring activities outlined in 2 CFR ? 200.332(d), this has created a scope limitation for the audit and has led the Auditor of Public Accounts to disclaim an opinion for the ERA federal grant program. Close out for the ERA1 federal award will occur in April 2023. Housing and Community Development should perform the required monitoring activities before it closes out the ERA1 federal award. If Housing and Community Development does not believe it will complete these monitoring activities before the ERA1 federal award close-out, it should work collaboratively with the United States Department of the Treasury to discuss alternate solutions for ensuring program compliance. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-013: Review Non-Locality Subrecipient Single Audit Reports Applicable to: Department of Social Services Prior Year Finding Number: 2021-072; 2020-075; 2019-091; 2018-092 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d)(3)(f) Known Questioned Costs: $0 Compliance continues to not review non-locality subrecipient Single Audit reports as established within its Agency Monitoring Plan. Non-locality subrecipients are subrecipients, who are not local governments, and are mainly comprised of non-profit organizations. During fiscal year 2022, Social Services disbursed approximately $80 million in federal funds to roughly 200 non-locality subrecipients. While reviewing the audit reports for the 27 non-locality subrecipients that received more than $750,000 in federal funds from Social Services, we noted the following: Five non-locality subrecipients (19%) did not have a current Single Audit report available in the Federal Audit Clearinghouse (Clearinghouse). Fiscal year 2022 federal disbursements to these non-locality subrecipients totaled approximately $6.5 million. Two non-locality subrecipients (7%) had audit findings that affected one or more of Social Services' federal grant programs. As a result of the lack of review over non- locality subrecipient Single Audit reports, Social Services did not issue management decision letters within six months of acceptance of the audit reports by the Clearinghouse to collaboratively resolve audit findings related to Social Services' federal programs. According to 2 CFR ? 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that subrecipient's federal awards expended during the respective fiscal year equaled or exceeded $750,000. Additionally, 2 CFR ? 200.332(d)(3) requires pass- through entities to issue management decisions for applicable audit findings within six months of acceptance of the audit report by the Clearinghouse. Without verifying whether non-locality subrecipients received a Single Audit report, Compliance is unable to provide assurance that Social Services met the audit requirements set forth in 2 CFR ? 200.332(d)(3) and (f). Additionally, Compliance cannot provide Social Services' Executive Team with assurance that its subrecipient monitoring efforts are adequate without reviewing non-locality Single Audit reports. Compliance did not review non-locality subrecipient Single Audit reports because it did not dedicate the resources necessary to implement corrective action. In its corrective action plan, Compliance planned to procure a centralized system to support its subrecipient monitoring efforts. However, Compliance was unable to procure a centralized system to support its subrecipient monitoring efforts during the fiscal year and it did not implement an alternative solution to comply with the requirements in 2 CFR ? 200.332(d)(3) and (f). Compliance should determine what alternative solutions are available, if it is unable to procure a centralized system, and start reviewing non-locality Single Audit reports to comply with the federal regulations in 2 CFR ? 200.332(d)(3) and (f). Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-015: Verify that Monitoring Plan Includes All Subrecipient Programmatic Activities Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b)(d) Known Questioned Costs: $0 Benefit Programs' monitoring plan does not include all subrecipient programmatic activities for the TANF federal grant program. Benefit Programs' primary programmatic activity for the TANF federal grant program is eligibility determination functions performed by local agencies. However, Benefit Programs also awards various competitive grants to local governments and non-profit organizations to help TANF recipients become self-sufficient. Benefit Programs did not include these programmatic activities in its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $47 million in TANF competitive grants to roughly 160 organizations. Title 2 CFR ? 200.332(b) requires all pass-through entities 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. Additionally, 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and achieves subaward performance goals. When Benefit Programs developed its monitoring plan, it only focused on eligibility functions performed by local agencies but did not consider other programmatic activities for the TANF federal grant program. Without including the other programmatic activities in the monitoring plan, Benefit Programs cannot provide assurance that subrecipients used TANF federal grant funds for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should update its monitoring plan to include all subrecipient programmatic activities for the TANF federal grant program and ensure each subrecipient is subject to the appropriate risk assessment procedures. Additionally, Benefit Programs should review its awards data for the federal grant programs under its purview to determine if it should include any other subrecipient programmatic activities in its monitoring plan. Benefit Programs' monitoring coordinators should then review the division's monitoring efforts to ensure program consultants conduct them in accordance with the risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-013: Review Non-Locality Subrecipient Single Audit Reports Applicable to: Department of Social Services Prior Year Finding Number: 2021-072; 2020-075; 2019-091; 2018-092 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d)(3)(f) Known Questioned Costs: $0 Compliance continues to not review non-locality subrecipient Single Audit reports as established within its Agency Monitoring Plan. Non-locality subrecipients are subrecipients, who are not local governments, and are mainly comprised of non-profit organizations. During fiscal year 2022, Social Services disbursed approximately $80 million in federal funds to roughly 200 non-locality subrecipients. While reviewing the audit reports for the 27 non-locality subrecipients that received more than $750,000 in federal funds from Social Services, we noted the following: Five non-locality subrecipients (19%) did not have a current Single Audit report available in the Federal Audit Clearinghouse (Clearinghouse). Fiscal year 2022 federal disbursements to these non-locality subrecipients totaled approximately $6.5 million. Two non-locality subrecipients (7%) had audit findings that affected one or more of Social Services' federal grant programs. As a result of the lack of review over non- locality subrecipient Single Audit reports, Social Services did not issue management decision letters within six months of acceptance of the audit reports by the Clearinghouse to collaboratively resolve audit findings related to Social Services' federal programs. According to 2 CFR ? 200.332(f), all pass-through entities must verify their subrecipients are audited if it is expected that subrecipient's federal awards expended during the respective fiscal year equaled or exceeded $750,000. Additionally, 2 CFR ? 200.332(d)(3) requires pass- through entities to issue management decisions for applicable audit findings within six months of acceptance of the audit report by the Clearinghouse. Without verifying whether non-locality subrecipients received a Single Audit report, Compliance is unable to provide assurance that Social Services met the audit requirements set forth in 2 CFR ? 200.332(d)(3) and (f). Additionally, Compliance cannot provide Social Services' Executive Team with assurance that its subrecipient monitoring efforts are adequate without reviewing non-locality Single Audit reports. Compliance did not review non-locality subrecipient Single Audit reports because it did not dedicate the resources necessary to implement corrective action. In its corrective action plan, Compliance planned to procure a centralized system to support its subrecipient monitoring efforts. However, Compliance was unable to procure a centralized system to support its subrecipient monitoring efforts during the fiscal year and it did not implement an alternative solution to comply with the requirements in 2 CFR ? 200.332(d)(3) and (f). Compliance should determine what alternative solutions are available, if it is unable to procure a centralized system, and start reviewing non-locality Single Audit reports to comply with the federal regulations in 2 CFR ? 200.332(d)(3) and (f). Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-015: Verify that Monitoring Plan Includes All Subrecipient Programmatic Activities Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b)(d) Known Questioned Costs: $0 Benefit Programs' monitoring plan does not include all subrecipient programmatic activities for the TANF federal grant program. Benefit Programs' primary programmatic activity for the TANF federal grant program is eligibility determination functions performed by local agencies. However, Benefit Programs also awards various competitive grants to local governments and non-profit organizations to help TANF recipients become self-sufficient. Benefit Programs did not include these programmatic activities in its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $47 million in TANF competitive grants to roughly 160 organizations. Title 2 CFR ? 200.332(b) requires all pass-through entities 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. Additionally, 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward; and achieves subaward performance goals. When Benefit Programs developed its monitoring plan, it only focused on eligibility functions performed by local agencies but did not consider other programmatic activities for the TANF federal grant program. Without including the other programmatic activities in the monitoring plan, Benefit Programs cannot provide assurance that subrecipients used TANF federal grant funds for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should update its monitoring plan to include all subrecipient programmatic activities for the TANF federal grant program and ensure each subrecipient is subject to the appropriate risk assessment procedures. Additionally, Benefit Programs should review its awards data for the federal grant programs under its purview to determine if it should include any other subrecipient programmatic activities in its monitoring plan. Benefit Programs' monitoring coordinators should then review the division's monitoring efforts to ensure program consultants conduct them in accordance with the risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-011: Perform Responsibilities Outlined in the Agency Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: 2021-070; 2020-074; 2019-090; 2018-093 Type of Finding: Internal Control and Compliance Severity of Deficiency: Material Weakness ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778 (COVID-19) Federal Award Number and Year: 2205VA5MAP - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.303(a) Known Questioned Costs: $0 The Department of Social Services' (Social Service) Compliance Division (Compliance) continues to not adhere to its established approach to oversee the agency's subrecipient monitoring activities, as outlined in its Agency Monitoring Plan. During fiscal year 2022, Social Services disbursed approximately $588 million in federal funds from roughly 5,000 subawards. According to Social Services' Organizational Structure Report, Compliance is responsible for agency-wide compliance and risk mitigation that helps to ensure adherence to state and federal legal and regulatory standards, including subrecipient monitoring. During the audit, we noted the following deviations from the Agency Monitoring Plan: ? Compliance has not finalized the Agency Monitoring Plan and, as a result, has not communicated it to Subrecipient Monitoring Coordinators within each division of Social Services. Because of the lack of communication, there were deviations from the Agency Monitoring Plan at the division level. For example, the Agency Monitoring Plan requires each division to monitor subrecipients once every three years. However, the Local Review Team and Child Care Subsidy Program Monitoring Plans did not consider this requirement because the Subrecipient Monitoring Coordinators were unaware of this requirement. We communicated this matter to Social Services through the audit finding titled "Finalize the Agency Monitoring Plan and Communicate Responsibilities to Subrecipient Monitoring Coordinators," which we have included as a separate audit finding in this report. ? Compliance continues to not review division monitoring plans to ensure the divisions implemented a risk-based approach for monitoring subrecipients. The Agency Monitoring Plan states that Compliance will use a monitoring plan checklist to evaluate and determine if all the required elements for subrecipient monitoring are present in each division's plan. As a result of the lack of review, the Division of Benefit Programs' (Benefit Programs) monitoring plan continues to not meet all the requirements outlined in the Agency Monitoring Plan because it does not include a risk-based approach for subrecipient monitoring and does not consider all subrecipients who receive funding from the Temporary Assistance for Needy Families (TANF) federal grant program. We communicated these matters to Social Services through the audit findings titled "Verify that Monitoring Plan Includes All Subrecipient Programmatic Activities" and "Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations," which we have included as separate audit findings in this report. ?Compliance continues to not conduct an analysis of subrecipient monitoring review efforts performed by the divisions. As a result, Compliance has not produced quarterly reports of variances and noncompliance to brief Social Services' Executive Team on the agency's subrecipient monitoring activities. Because of the lack of analysis, Compliance was unaware of deviations from the Agency Monitoring Plan occurring at the divisions. For example, Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the Low-Income Home Energy Assistance Program (LIHEAP) federal grant program. Additionally, Benefit Programs did not upload its monitoring review records to Social Services' data repository timely for management review. As a result, Compliance was unaware that Regional Consultants were deviating from Benefit Programs' monitoring plan. We communicated this matter to Social Services through the audit finding titled "Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan," which we have included as a separate audit finding in this report. Without performing the responsibilities in the Agency Monitoring Plan, Compliance cannot provide Social Services' Executive Team with reasonable assurance that the agency complied with the pass-through entity federal requirements at 2 CFR ? 200.332. Title 2 CFR ? 200.303(a) requires pass through entities to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Compliance planned to procure a centralized system to strengthen its monitoring activities but has been unsuccessful in its efforts and has not identified alternative approaches for carrying out the responsibilities in the Agency Monitoring Plan and discussed them with Social Services' Executive Team. Because of the scope of this matter, we consider it to be a material weakness in internal control. Social Services' Executive Team shapes strategies, develops objectives, and collectively resolves issues that are critical to the overall agency performance. Social Services' Executive Team and Compliance should work collaboratively to determine the best approach for carrying out the responsibilities in the Agency Monitoring Plan. Additionally, Social Services' Executive Team and Compliance should hold quarterly meetings to discuss the Agency Monitoring Plan and its activities. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-012: Finalize the Agency Monitoring Plan and Communicate Responsibilities to Subrecipient Monitoring Coordinators Applicable to: Department of Social Services Prior Year Finding Number: 2021-069; 2020-076 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778 (COVID-19) Federal Award Number and Year: 2205VA5MAP - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Compliance has not finalized its Agency Monitoring Plan and communicated responsibilities to Subrecipient Monitoring Coordinators, as recommended during the fiscal year 2020 audit. The oversight of Social Services' subrecipient monitoring processes transitioned from the Division of Community and Volunteer Services (Community and Volunteer Services) to Compliance in fiscal year 2019. Community and Volunteer Services created the Agency Monitoring Plan, and it is now the responsibility of Compliance. However, Compliance has not updated the Agency Monitoring Plan to properly reflect agency operations over subrecipient monitoring. In effect, Compliance continues to not communicate the Agency Monitoring Plan to Subrecipient Monitoring Coordinators within each division of Social Services. During fiscal year 2022, Social Services disbursed approximately $588 million in federal funds from roughly 5,000 subawards. Title 2 CFR ? 200.332(d) requires pass-through entities to monitor the activities of subrecipients as necessary to ensure use of the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without clearly defining responsibilities and communicating federal requirements, Compliance cannot provide assurance that Social Services adequately monitors all its subrecipients to ensure they are achieving program objectives or complying with federal requirements. Compliance was unable to finalize the monitoring plan and communicate responsibilities to monitoring coordinators because it did not dedicate the resources necessary to implement corrective action. Compliance should allocate resources to finalize the Agency Monitoring Plan to properly address subrecipient monitoring responsibilities. Additionally, Compliance should communicate the Agency Monitoring Plan to Subrecipient Monitoring Coordinators within each division of Social Services. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-011: Perform Responsibilities Outlined in the Agency Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: 2021-070; 2020-074; 2019-090; 2018-093 Type of Finding: Internal Control and Compliance Severity of Deficiency: Material Weakness ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778 (COVID-19) Federal Award Number and Year: 2205VA5MAP - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.303(a) Known Questioned Costs: $0 The Department of Social Services' (Social Service) Compliance Division (Compliance) continues to not adhere to its established approach to oversee the agency's subrecipient monitoring activities, as outlined in its Agency Monitoring Plan. During fiscal year 2022, Social Services disbursed approximately $588 million in federal funds from roughly 5,000 subawards. According to Social Services' Organizational Structure Report, Compliance is responsible for agency-wide compliance and risk mitigation that helps to ensure adherence to state and federal legal and regulatory standards, including subrecipient monitoring. During the audit, we noted the following deviations from the Agency Monitoring Plan: ? Compliance has not finalized the Agency Monitoring Plan and, as a result, has not communicated it to Subrecipient Monitoring Coordinators within each division of Social Services. Because of the lack of communication, there were deviations from the Agency Monitoring Plan at the division level. For example, the Agency Monitoring Plan requires each division to monitor subrecipients once every three years. However, the Local Review Team and Child Care Subsidy Program Monitoring Plans did not consider this requirement because the Subrecipient Monitoring Coordinators were unaware of this requirement. We communicated this matter to Social Services through the audit finding titled "Finalize the Agency Monitoring Plan and Communicate Responsibilities to Subrecipient Monitoring Coordinators," which we have included as a separate audit finding in this report. ? Compliance continues to not review division monitoring plans to ensure the divisions implemented a risk-based approach for monitoring subrecipients. The Agency Monitoring Plan states that Compliance will use a monitoring plan checklist to evaluate and determine if all the required elements for subrecipient monitoring are present in each division's plan. As a result of the lack of review, the Division of Benefit Programs' (Benefit Programs) monitoring plan continues to not meet all the requirements outlined in the Agency Monitoring Plan because it does not include a risk-based approach for subrecipient monitoring and does not consider all subrecipients who receive funding from the Temporary Assistance for Needy Families (TANF) federal grant program. We communicated these matters to Social Services through the audit findings titled "Verify that Monitoring Plan Includes All Subrecipient Programmatic Activities" and "Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations," which we have included as separate audit findings in this report. ?Compliance continues to not conduct an analysis of subrecipient monitoring review efforts performed by the divisions. As a result, Compliance has not produced quarterly reports of variances and noncompliance to brief Social Services' Executive Team on the agency's subrecipient monitoring activities. Because of the lack of analysis, Compliance was unaware of deviations from the Agency Monitoring Plan occurring at the divisions. For example, Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the Low-Income Home Energy Assistance Program (LIHEAP) federal grant program. Additionally, Benefit Programs did not upload its monitoring review records to Social Services' data repository timely for management review. As a result, Compliance was unaware that Regional Consultants were deviating from Benefit Programs' monitoring plan. We communicated this matter to Social Services through the audit finding titled "Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan," which we have included as a separate audit finding in this report. Without performing the responsibilities in the Agency Monitoring Plan, Compliance cannot provide Social Services' Executive Team with reasonable assurance that the agency complied with the pass-through entity federal requirements at 2 CFR ? 200.332. Title 2 CFR ? 200.303(a) requires pass through entities to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Compliance planned to procure a centralized system to strengthen its monitoring activities but has been unsuccessful in its efforts and has not identified alternative approaches for carrying out the responsibilities in the Agency Monitoring Plan and discussed them with Social Services' Executive Team. Because of the scope of this matter, we consider it to be a material weakness in internal control. Social Services' Executive Team shapes strategies, develops objectives, and collectively resolves issues that are critical to the overall agency performance. Social Services' Executive Team and Compliance should work collaboratively to determine the best approach for carrying out the responsibilities in the Agency Monitoring Plan. Additionally, Social Services' Executive Team and Compliance should hold quarterly meetings to discuss the Agency Monitoring Plan and its activities. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-012: Finalize the Agency Monitoring Plan and Communicate Responsibilities to Subrecipient Monitoring Coordinators Applicable to: Department of Social Services Prior Year Finding Number: 2021-069; 2020-076 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778 (COVID-19) Federal Award Number and Year: 2205VA5MAP - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Compliance has not finalized its Agency Monitoring Plan and communicated responsibilities to Subrecipient Monitoring Coordinators, as recommended during the fiscal year 2020 audit. The oversight of Social Services' subrecipient monitoring processes transitioned from the Division of Community and Volunteer Services (Community and Volunteer Services) to Compliance in fiscal year 2019. Community and Volunteer Services created the Agency Monitoring Plan, and it is now the responsibility of Compliance. However, Compliance has not updated the Agency Monitoring Plan to properly reflect agency operations over subrecipient monitoring. In effect, Compliance continues to not communicate the Agency Monitoring Plan to Subrecipient Monitoring Coordinators within each division of Social Services. During fiscal year 2022, Social Services disbursed approximately $588 million in federal funds from roughly 5,000 subawards. Title 2 CFR ? 200.332(d) requires pass-through entities to monitor the activities of subrecipients as necessary to ensure use of the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without clearly defining responsibilities and communicating federal requirements, Compliance cannot provide assurance that Social Services adequately monitors all its subrecipients to ensure they are achieving program objectives or complying with federal requirements. Compliance was unable to finalize the monitoring plan and communicate responsibilities to monitoring coordinators because it did not dedicate the resources necessary to implement corrective action. Compliance should allocate resources to finalize the Agency Monitoring Plan to properly address subrecipient monitoring responsibilities. Additionally, Compliance should communicate the Agency Monitoring Plan to Subrecipient Monitoring Coordinators within each division of Social Services. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-011: Perform Responsibilities Outlined in the Agency Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: 2021-070; 2020-074; 2019-090; 2018-093 Type of Finding: Internal Control and Compliance Severity of Deficiency: Material Weakness ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778 (COVID-19) Federal Award Number and Year: 2205VA5MAP - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.303(a) Known Questioned Costs: $0 The Department of Social Services' (Social Service) Compliance Division (Compliance) continues to not adhere to its established approach to oversee the agency's subrecipient monitoring activities, as outlined in its Agency Monitoring Plan. During fiscal year 2022, Social Services disbursed approximately $588 million in federal funds from roughly 5,000 subawards. According to Social Services' Organizational Structure Report, Compliance is responsible for agency-wide compliance and risk mitigation that helps to ensure adherence to state and federal legal and regulatory standards, including subrecipient monitoring. During the audit, we noted the following deviations from the Agency Monitoring Plan: ? Compliance has not finalized the Agency Monitoring Plan and, as a result, has not communicated it to Subrecipient Monitoring Coordinators within each division of Social Services. Because of the lack of communication, there were deviations from the Agency Monitoring Plan at the division level. For example, the Agency Monitoring Plan requires each division to monitor subrecipients once every three years. However, the Local Review Team and Child Care Subsidy Program Monitoring Plans did not consider this requirement because the Subrecipient Monitoring Coordinators were unaware of this requirement. We communicated this matter to Social Services through the audit finding titled "Finalize the Agency Monitoring Plan and Communicate Responsibilities to Subrecipient Monitoring Coordinators," which we have included as a separate audit finding in this report. ? Compliance continues to not review division monitoring plans to ensure the divisions implemented a risk-based approach for monitoring subrecipients. The Agency Monitoring Plan states that Compliance will use a monitoring plan checklist to evaluate and determine if all the required elements for subrecipient monitoring are present in each division's plan. As a result of the lack of review, the Division of Benefit Programs' (Benefit Programs) monitoring plan continues to not meet all the requirements outlined in the Agency Monitoring Plan because it does not include a risk-based approach for subrecipient monitoring and does not consider all subrecipients who receive funding from the Temporary Assistance for Needy Families (TANF) federal grant program. We communicated these matters to Social Services through the audit findings titled "Verify that Monitoring Plan Includes All Subrecipient Programmatic Activities" and "Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations," which we have included as separate audit findings in this report. ?Compliance continues to not conduct an analysis of subrecipient monitoring review efforts performed by the divisions. As a result, Compliance has not produced quarterly reports of variances and noncompliance to brief Social Services' Executive Team on the agency's subrecipient monitoring activities. Because of the lack of analysis, Compliance was unaware of deviations from the Agency Monitoring Plan occurring at the divisions. For example, Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the Low-Income Home Energy Assistance Program (LIHEAP) federal grant program. Additionally, Benefit Programs did not upload its monitoring review records to Social Services' data repository timely for management review. As a result, Compliance was unaware that Regional Consultants were deviating from Benefit Programs' monitoring plan. We communicated this matter to Social Services through the audit finding titled "Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan," which we have included as a separate audit finding in this report. Without performing the responsibilities in the Agency Monitoring Plan, Compliance cannot provide Social Services' Executive Team with reasonable assurance that the agency complied with the pass-through entity federal requirements at 2 CFR ? 200.332. Title 2 CFR ? 200.303(a) requires pass through entities to establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Compliance planned to procure a centralized system to strengthen its monitoring activities but has been unsuccessful in its efforts and has not identified alternative approaches for carrying out the responsibilities in the Agency Monitoring Plan and discussed them with Social Services' Executive Team. Because of the scope of this matter, we consider it to be a material weakness in internal control. Social Services' Executive Team shapes strategies, develops objectives, and collectively resolves issues that are critical to the overall agency performance. Social Services' Executive Team and Compliance should work collaboratively to determine the best approach for carrying out the responsibilities in the Agency Monitoring Plan. Additionally, Social Services' Executive Team and Compliance should hold quarterly meetings to discuss the Agency Monitoring Plan and its activities. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-012: Finalize the Agency Monitoring Plan and Communicate Responsibilities to Subrecipient Monitoring Coordinators Applicable to: Department of Social Services Prior Year Finding Number: 2021-069; 2020-076 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778 (COVID-19) Federal Award Number and Year: 2205VA5MAP - 2022 Name of Federal Agency: U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Compliance has not finalized its Agency Monitoring Plan and communicated responsibilities to Subrecipient Monitoring Coordinators, as recommended during the fiscal year 2020 audit. The oversight of Social Services' subrecipient monitoring processes transitioned from the Division of Community and Volunteer Services (Community and Volunteer Services) to Compliance in fiscal year 2019. Community and Volunteer Services created the Agency Monitoring Plan, and it is now the responsibility of Compliance. However, Compliance has not updated the Agency Monitoring Plan to properly reflect agency operations over subrecipient monitoring. In effect, Compliance continues to not communicate the Agency Monitoring Plan to Subrecipient Monitoring Coordinators within each division of Social Services. During fiscal year 2022, Social Services disbursed approximately $588 million in federal funds from roughly 5,000 subawards. Title 2 CFR ? 200.332(d) requires pass-through entities to monitor the activities of subrecipients as necessary to ensure use of the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without clearly defining responsibilities and communicating federal requirements, Compliance cannot provide assurance that Social Services adequately monitors all its subrecipients to ensure they are achieving program objectives or complying with federal requirements. Compliance was unable to finalize the monitoring plan and communicate responsibilities to monitoring coordinators because it did not dedicate the resources necessary to implement corrective action. Compliance should allocate resources to finalize the Agency Monitoring Plan to properly address subrecipient monitoring responsibilities. Additionally, Compliance should communicate the Agency Monitoring Plan to Subrecipient Monitoring Coordinators within each division of Social Services. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-014: Confirm Monitoring Activities are Conducted in Accordance with the Monitoring Plan Applicable to: Department of Social Services Prior Year Finding Number: N/A Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(d) Known Questioned Costs: $0 Benefit Programs does not oversee subrecipient monitoring activities to ensure monitoring activities are conducted in accordance with its monitoring plan. During the fiscal year, Benefit Programs disbursed approximately $312 million in subaward payments from the Supplemental Nutrition Assistance Program (SNAP) and Medicaid Clusters and the LIHEAP and TANF federal grant programs. During the audit, we noted the following deviations from Benefit Program's monitoring plan: ? Benefit Programs created a monitoring plan to comply with Social Services' Agency Monitoring Plan. Regional consultants, who perform subrecipient monitoring activities, created their own subrecipient monitoring schedules that were not consistent with Benefit Program's monitoring schedule. ? Benefit Programs did not confirm that fiscal year 2022 monitoring review records uploaded to its data repository were complete. Some of the missing records included the agency notification letter, case selection sample, and subrecipient monitoring checklist. ? At the beginning of audit fieldwork, the data repository did not contain all subrecipient monitoring reviews performed during the fiscal year. The Subrecipient Monitoring Coordinator subsequently obtained and uploaded the remaining subrecipient monitoring reviews to Benefit Programs' data repository. The data repository only included the following subrecipient monitoring reviews at the time of the audit: o 12 of 25 (48%) reviews performed for the LIHEAP federal grant program; o 22 of 73 (30%) reviews performed for the SNAP Cluster; o 13 of 62 (21%) reviews performed for the Medicaid Cluster; and nine of 62 (15%) reviews performed for the TANF federal grant program. Benefit Programs only completed 25 of the 67 (37%) scheduled reviews for the LIHEAP federal grant program. Benefit Programs did not identify these issues because its monitoring plan did not clearly delineate who was responsible for overseeing subrecipient monitoring activities. As a result, no one in Benefit Programs was overseeing subrecipient monitoring activities. Title 2 CFR ? 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient as necessary to ensure that the pass-through entity uses the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Without confirming that program consultants conduct monitoring activities in accordance with the monitoring plan, Benefit Programs cannot provide assurance that it complied with 2 CFR ? 200.332(d). In March 2022, Benefit Programs created a Subrecipient Monitoring Coordinator position to oversee its monitoring activities. The Subrecipient Monitoring Coordinator is working with Benefit Program?s Associate Director for Operations and Support to confirm that Benefit Programs? monitoring plan meets federal requirements. Benefit Programs should continue its efforts to confirm that it conducts monitoring activities in accordance with its monitoring plan. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
2022-016: Evaluate Subrecipients' Risk of Noncompliance in Accordance with Federal Regulations Applicable to: Department of Social Services Prior Year Finding Number: 2021-071 Type of Finding: Internal Control and Compliance Severity of Deficiency: Significant Deficiency ALPT or Cluster Name and ALN: Medicaid Cluster - 93.775, 93.777, 93.778; SNAP Cluster - 10.551, 10.561; Temporary Assistance for Needy Families (TANF) - 93.558 (COVID-19) Federal Award Number and Year: 2205VA5MAP; 221VA407S2514; 2201VATANF - 2022 Name of Federal Agency: U.S. Department of Agriculture; U.S. Department of Health and Human Services Type of Compliance Requirement - Criteria: Subrecipient Monitoring - 2 CFR ? 200.332(b) Known Questioned Costs: $0 Benefit Programs continues to not evaluate subrecipients' risk of noncompliance with federal regulations related to the administration of the SNAP and Medicaid Clusters and the TANF and LIHEAP federal grant programs. Benefit Programs develops its subrecipient monitoring approach using the size of the subrecipient; however, it does not perform any further risk assessment procedures to determine the monitoring approach. Social Services disbursed approximately $312 million to subrecipients from these federal programs during the fiscal year. Title 2 CFR ? 200.332(b) requires pass-through entities 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. Further, 2 CFR ? 200.332(b) suggests that pass-through entities should consider the results of previous audits, subrecipient's prior experience with the same or similar subawards, and whether the subrecipient has new personnel or new or substantially changed systems. Benefit Programs developed a corrective action plan to perform risk assessment procedures to comply with 2 CFR ? 200.332(b); however, Benefit Programs was unable to implement corrective action due to staff turnover. Without performing the proper risk assessment procedures, Benefit Programs cannot demonstrate that it monitored the activities of the subrecipient as necessary to ensure that the pass-through entity used the subaward for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Benefit Programs should continue its corrective action efforts to implement a risk assessment process for subrecipients that is consistent with federal regulations and ensure that its monitoring efforts are consistent with the results of its risk assessment. Views of Responsible Officials: Views of responsible officials are in the report related to their agency, which can be found at www.apa.virginia.gov. In summary, the views of responsible officials in the agency report do not express a disagreement with the finding.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 2 CFR 200.332(f) requires pass-through entities to ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.
Reference Number: 2022-005 Federal Program Title: Coronavirus Relief Fund Federal Assistance Listing Number: 21.019 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2021-22 Name of Department: County Executive Office Category of Finding: Subrecipient Monitoring Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) ?200.332, all pass-through entities (PTE) must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i.) Subrecipient name (which must match the name associated with its unique entity identifier); (ii.) Subrecipient's unique entity identifier; (iii.) Federal Award Identification Number (FAIN); (iv.) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v.) Subaward Period of Performance Start and End Date; (vi.) Subaward Budget Period Start and End Date; (vii.) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii.) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix.) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x.) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi.) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii.) Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii.) Identification of whether the award is R&D; and (xiv.) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Condition During our audit of the Coronavirus Relief Fund (CRF) program, we selected three (3) subrecipients with active contracts with the County during FY 2021-22. Two (2) of the contracts administered by the Chief Executive Office (CEO) did not include one or more of the required elements defined in 2 CFR ?200.332 (a)(1)(2)(3)(5) and (6) in the subrecipients? agreements. The subrecipient agreements indicated that reporting was required, but were both vague and not consistent as to the level of detail or timing of when reports were due. The subrecipients selected did submit reports to the respective contracting departments for review; however, the information provided was not in a uniform and consistent format making it difficult to determine compliance with program expectations without requesting additional documentation. Furthermore, the County?s internal policy for entities doing business with the County, including subrecipients, requires that contracts and agreements include data encryption terms. None of the agreements included these requirements and per inquiry of the departments, staff were not aware of the requirement. This is a repeat finding of 2021-009. Cause The CRF program was a new program in FY 2020-21 and due to the challenges of remote work and other resource constraints of the COVID-19 pandemic, the County had difficulty coordinating the distribution of funds to comply with administrative requirements and focused on getting the monies out to the communities in need. Effect Failure to provide all the required subaward information may result in subrecipients incorrectly reporting on federal pass-through awards in their Single Audit reports. Furthermore, not communicating clear expectations on reporting requirements may result in subrecipients claiming unallowed costs that are not detected timely. Questioned Costs Questioned costs were not determinable. Context For two (2) of the three (3) subrecipients selected for testing, which totaled $15,976,682 from a population of fifty-nine (59) subrecipients with expenditures totaling $24,905,874, the departments did not communicate all of the required subaward data elements or communicate clear expectations on reporting requirements. The sample was not a statistically valid sample. Recommendation We recommend the County perform the following: 1. Design a subrecipient agreement template to include all the elements required by 2 CFR ?200.332(a) and any other County required elements (e.g., data encryption requirements) and incorporate the use of the template in the contracting requirements for all departments. 2. For existing subrecipients that were not provided the required elements, provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a). 3. Include clear expectations for periodic reporting by subrecipients in the subrecipient agreement, including level of detail and timing of submission.
2022-010 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: None AL Number and Title: 84.027 ? Special Education Grants to States 84.173 ? Special Education Preschool Grants 84.287 ? Twenty-First Century Community Learning Centers 84.367 ? Supporting Effective Instruction State Grants 84.425C ? COVID-19 ? Governor?s Emergency Education Relief Fund 84.425D ? COVID-19 ? Elementary and Secondary Emergency Relief (ESSER) Fund 84.425R ? COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) 84.425U ? COVID-19 ? American Rescue Plan ? Elementary and Secondary Emergency Relief (ARP ESSER) Federal Award Number: H027A180073 (Year: 2019), H027A190073 (Year: 2020), H027A200073 (Year: 2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A180081 (Year: 2019), H173A190081 (Year: 2020), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022), S287C1900010 (Year: 2020), S287C200010 (Year 2021), S287C210010 (Year: 2022), S367A190001 (Year: 2020), S367A20001 (Year: 2021), S367A210001 (Year: 2022), S425C200049 (Year: 2021), S425C210049 (Year: 2021), S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425R210034 (Year: 2021), S425U210012-21A (Year: 2021) Questioned Costs: None Identified Description: The Georgia Department of Education should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Special Education Cluster, which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). Special Education Cluster funding is available to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities. The Twenty-First Century Community Learning Centers (21st CCLC) program was created by the Elementary and Secondary Education Act of 1965 to establish or expand community learning centers that provide students with academic enrichment opportunities during non-school hours or periods when school is not in session. These community learning centers provide services to support student learning and development, including tutoring and mentoring, homework help, academic enrichment, community service opportunities, and music, arts, sports, and cultural activities. The Supporting Effective Instruction State Grants (Title II, Part A) program was created by the Elementary and Secondary Education Act of 1965 to provide funds to state educational agencies and local educational agencies to increase student achievement consistent with the challenging state academic standards; improve the quality and effectiveness of teachers, principals, and other school leaders; increase the number of teachers, principals, and other school leaders who are effective in improving student academic achievement in schools; and provide low-income and minority students greater access to effective teachers, principals, and other school leaders. The Education Stabilization Fund (ESF) was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. Various ESF subprograms were created and allotted funding through COVID-19-related legislation. Many of these subprograms were designed to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. These subprograms include the Elementary and Secondary School Emergency Relief (ESSER) Fund, American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER), and Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public School (CRRSA EANS) programs. Additionally, elementary and secondary schools were allotted funding through the Governor?s Emergency Education Relief (GEER) Fund, which allocated resources to governors to provide emergency assistance to education-related-entities. Funds associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF subprograms are provided to the Georgia Department of Education (GaDOE) for allocation to eligible subrecipients. Because the GaDOE subgrants program funds to various entities, the GaDOE must perform certain monitoring activities related to these subrecipients. Criteria: As a recipient of federal awards, the GaDOE is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that ?All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes? [required] information at the time of the subaward? (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through monitoring of the subrecipient must include? (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the passthrough entity? (f) Verify that every subrecipient is audited as required by Subpart F ? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth? (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement against noncompliant subrecipients.? Condition: Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: ? A sample of 23 subrecipients associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF program was randomly selected for testing using a non-statistical sampling method. Auditors examined documentation to determine if the GaDOE had reviewed the results of each subrecipient?s audits appropriately; however, this testing revealed that one of the audits was not obtained or reviewed by the GaDOE as required. Additionally, the GaDOE could not provide documentation that the results of this audit were considered in the risk assessment process and followed up on to ensure that the subrecipient took appropriate and timely action to correct any deficiencies noted in the audit. ? A sample of seven subrecipients associated with the 21st CCLC program was selected for testing using a non-statistical sampling method. Auditors reviewed documentation to determine if appropriate monitoring was conducted over these subrecipients in accordance with the GaDOE?s internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one subrecipient tested. ? A sample of 23 subawards related to the Special Education Cluster was randomly selected for testing using a non-statistical sampling method. These subawards were reviewed to determine if all required components were included; however, this testing revealed that the subrecipient?s unique entity identifier was omitted from the subaward document in three instances. Cause: The GaDOE stated that the responsibility for maintaining documentation for audits of non-profit subrecipients was shifted to a new department due to the elimination of positions during the pandemic and was inadvertently overlooked. Additionally, the GaDOE stated that though other monitoring activities associated with the 21st CCLC program were performed, cross-functional monitoring and a site visit was not performed due to the fact that it was the last year that this particular subrecipient would be funded. Furthermore, the spreadsheet used to accumulate all subrecipient information did not include the UEI for three subrecipients due to the fact that the UEI requirement was recently implemented and the GaDOE experienced difficulty in obtaining the numbers. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal funds being expended for unallowable purposes, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the GaDOE: ? Follow established policies and procedures to ensure that subrecipients receive audits when necessary, the results of these audits are considered in the risk assessment process, and timely management decisions are made for any audit findings pertaining to federal awards; ? Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements; and ? Update the spreadsheet used to accumulate all subrecipient information to ensure that all subaward documents include the required components reflected within the Uniform Guidance. Views of Responsible Officials: We concur with this finding. We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs LEA audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st CCLC Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators.
2022-010 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: None AL Number and Title: 84.027 ? Special Education Grants to States 84.173 ? Special Education Preschool Grants 84.287 ? Twenty-First Century Community Learning Centers 84.367 ? Supporting Effective Instruction State Grants 84.425C ? COVID-19 ? Governor?s Emergency Education Relief Fund 84.425D ? COVID-19 ? Elementary and Secondary Emergency Relief (ESSER) Fund 84.425R ? COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) 84.425U ? COVID-19 ? American Rescue Plan ? Elementary and Secondary Emergency Relief (ARP ESSER) Federal Award Number: H027A180073 (Year: 2019), H027A190073 (Year: 2020), H027A200073 (Year: 2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A180081 (Year: 2019), H173A190081 (Year: 2020), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022), S287C1900010 (Year: 2020), S287C200010 (Year 2021), S287C210010 (Year: 2022), S367A190001 (Year: 2020), S367A20001 (Year: 2021), S367A210001 (Year: 2022), S425C200049 (Year: 2021), S425C210049 (Year: 2021), S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425R210034 (Year: 2021), S425U210012-21A (Year: 2021) Questioned Costs: None Identified Description: The Georgia Department of Education should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Special Education Cluster, which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). Special Education Cluster funding is available to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities. The Twenty-First Century Community Learning Centers (21st CCLC) program was created by the Elementary and Secondary Education Act of 1965 to establish or expand community learning centers that provide students with academic enrichment opportunities during non-school hours or periods when school is not in session. These community learning centers provide services to support student learning and development, including tutoring and mentoring, homework help, academic enrichment, community service opportunities, and music, arts, sports, and cultural activities. The Supporting Effective Instruction State Grants (Title II, Part A) program was created by the Elementary and Secondary Education Act of 1965 to provide funds to state educational agencies and local educational agencies to increase student achievement consistent with the challenging state academic standards; improve the quality and effectiveness of teachers, principals, and other school leaders; increase the number of teachers, principals, and other school leaders who are effective in improving student academic achievement in schools; and provide low-income and minority students greater access to effective teachers, principals, and other school leaders. The Education Stabilization Fund (ESF) was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. Various ESF subprograms were created and allotted funding through COVID-19-related legislation. Many of these subprograms were designed to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. These subprograms include the Elementary and Secondary School Emergency Relief (ESSER) Fund, American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER), and Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public School (CRRSA EANS) programs. Additionally, elementary and secondary schools were allotted funding through the Governor?s Emergency Education Relief (GEER) Fund, which allocated resources to governors to provide emergency assistance to education-related-entities. Funds associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF subprograms are provided to the Georgia Department of Education (GaDOE) for allocation to eligible subrecipients. Because the GaDOE subgrants program funds to various entities, the GaDOE must perform certain monitoring activities related to these subrecipients. Criteria: As a recipient of federal awards, the GaDOE is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that ?All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes? [required] information at the time of the subaward? (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through monitoring of the subrecipient must include? (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the passthrough entity? (f) Verify that every subrecipient is audited as required by Subpart F ? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth? (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement against noncompliant subrecipients.? Condition: Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: ? A sample of 23 subrecipients associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF program was randomly selected for testing using a non-statistical sampling method. Auditors examined documentation to determine if the GaDOE had reviewed the results of each subrecipient?s audits appropriately; however, this testing revealed that one of the audits was not obtained or reviewed by the GaDOE as required. Additionally, the GaDOE could not provide documentation that the results of this audit were considered in the risk assessment process and followed up on to ensure that the subrecipient took appropriate and timely action to correct any deficiencies noted in the audit. ? A sample of seven subrecipients associated with the 21st CCLC program was selected for testing using a non-statistical sampling method. Auditors reviewed documentation to determine if appropriate monitoring was conducted over these subrecipients in accordance with the GaDOE?s internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one subrecipient tested. ? A sample of 23 subawards related to the Special Education Cluster was randomly selected for testing using a non-statistical sampling method. These subawards were reviewed to determine if all required components were included; however, this testing revealed that the subrecipient?s unique entity identifier was omitted from the subaward document in three instances. Cause: The GaDOE stated that the responsibility for maintaining documentation for audits of non-profit subrecipients was shifted to a new department due to the elimination of positions during the pandemic and was inadvertently overlooked. Additionally, the GaDOE stated that though other monitoring activities associated with the 21st CCLC program were performed, cross-functional monitoring and a site visit was not performed due to the fact that it was the last year that this particular subrecipient would be funded. Furthermore, the spreadsheet used to accumulate all subrecipient information did not include the UEI for three subrecipients due to the fact that the UEI requirement was recently implemented and the GaDOE experienced difficulty in obtaining the numbers. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal funds being expended for unallowable purposes, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the GaDOE: ? Follow established policies and procedures to ensure that subrecipients receive audits when necessary, the results of these audits are considered in the risk assessment process, and timely management decisions are made for any audit findings pertaining to federal awards; ? Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements; and ? Update the spreadsheet used to accumulate all subrecipient information to ensure that all subaward documents include the required components reflected within the Uniform Guidance. Views of Responsible Officials: We concur with this finding. We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs LEA audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st CCLC Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators.
2022-010 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: None AL Number and Title: 84.027 ? Special Education Grants to States 84.173 ? Special Education Preschool Grants 84.287 ? Twenty-First Century Community Learning Centers 84.367 ? Supporting Effective Instruction State Grants 84.425C ? COVID-19 ? Governor?s Emergency Education Relief Fund 84.425D ? COVID-19 ? Elementary and Secondary Emergency Relief (ESSER) Fund 84.425R ? COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) 84.425U ? COVID-19 ? American Rescue Plan ? Elementary and Secondary Emergency Relief (ARP ESSER) Federal Award Number: H027A180073 (Year: 2019), H027A190073 (Year: 2020), H027A200073 (Year: 2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A180081 (Year: 2019), H173A190081 (Year: 2020), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022), S287C1900010 (Year: 2020), S287C200010 (Year 2021), S287C210010 (Year: 2022), S367A190001 (Year: 2020), S367A20001 (Year: 2021), S367A210001 (Year: 2022), S425C200049 (Year: 2021), S425C210049 (Year: 2021), S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425R210034 (Year: 2021), S425U210012-21A (Year: 2021) Questioned Costs: None Identified Description: The Georgia Department of Education should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Special Education Cluster, which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). Special Education Cluster funding is available to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities. The Twenty-First Century Community Learning Centers (21st CCLC) program was created by the Elementary and Secondary Education Act of 1965 to establish or expand community learning centers that provide students with academic enrichment opportunities during non-school hours or periods when school is not in session. These community learning centers provide services to support student learning and development, including tutoring and mentoring, homework help, academic enrichment, community service opportunities, and music, arts, sports, and cultural activities. The Supporting Effective Instruction State Grants (Title II, Part A) program was created by the Elementary and Secondary Education Act of 1965 to provide funds to state educational agencies and local educational agencies to increase student achievement consistent with the challenging state academic standards; improve the quality and effectiveness of teachers, principals, and other school leaders; increase the number of teachers, principals, and other school leaders who are effective in improving student academic achievement in schools; and provide low-income and minority students greater access to effective teachers, principals, and other school leaders. The Education Stabilization Fund (ESF) was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. Various ESF subprograms were created and allotted funding through COVID-19-related legislation. Many of these subprograms were designed to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. These subprograms include the Elementary and Secondary School Emergency Relief (ESSER) Fund, American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER), and Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public School (CRRSA EANS) programs. Additionally, elementary and secondary schools were allotted funding through the Governor?s Emergency Education Relief (GEER) Fund, which allocated resources to governors to provide emergency assistance to education-related-entities. Funds associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF subprograms are provided to the Georgia Department of Education (GaDOE) for allocation to eligible subrecipients. Because the GaDOE subgrants program funds to various entities, the GaDOE must perform certain monitoring activities related to these subrecipients. Criteria: As a recipient of federal awards, the GaDOE is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that ?All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes? [required] information at the time of the subaward? (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through monitoring of the subrecipient must include? (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the passthrough entity? (f) Verify that every subrecipient is audited as required by Subpart F ? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth? (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement against noncompliant subrecipients.? Condition: Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: ? A sample of 23 subrecipients associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF program was randomly selected for testing using a non-statistical sampling method. Auditors examined documentation to determine if the GaDOE had reviewed the results of each subrecipient?s audits appropriately; however, this testing revealed that one of the audits was not obtained or reviewed by the GaDOE as required. Additionally, the GaDOE could not provide documentation that the results of this audit were considered in the risk assessment process and followed up on to ensure that the subrecipient took appropriate and timely action to correct any deficiencies noted in the audit. ? A sample of seven subrecipients associated with the 21st CCLC program was selected for testing using a non-statistical sampling method. Auditors reviewed documentation to determine if appropriate monitoring was conducted over these subrecipients in accordance with the GaDOE?s internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one subrecipient tested. ? A sample of 23 subawards related to the Special Education Cluster was randomly selected for testing using a non-statistical sampling method. These subawards were reviewed to determine if all required components were included; however, this testing revealed that the subrecipient?s unique entity identifier was omitted from the subaward document in three instances. Cause: The GaDOE stated that the responsibility for maintaining documentation for audits of non-profit subrecipients was shifted to a new department due to the elimination of positions during the pandemic and was inadvertently overlooked. Additionally, the GaDOE stated that though other monitoring activities associated with the 21st CCLC program were performed, cross-functional monitoring and a site visit was not performed due to the fact that it was the last year that this particular subrecipient would be funded. Furthermore, the spreadsheet used to accumulate all subrecipient information did not include the UEI for three subrecipients due to the fact that the UEI requirement was recently implemented and the GaDOE experienced difficulty in obtaining the numbers. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal funds being expended for unallowable purposes, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the GaDOE: ? Follow established policies and procedures to ensure that subrecipients receive audits when necessary, the results of these audits are considered in the risk assessment process, and timely management decisions are made for any audit findings pertaining to federal awards; ? Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements; and ? Update the spreadsheet used to accumulate all subrecipient information to ensure that all subaward documents include the required components reflected within the Uniform Guidance. Views of Responsible Officials: We concur with this finding. We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs LEA audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st CCLC Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators.
2022-010 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: None AL Number and Title: 84.027 ? Special Education Grants to States 84.173 ? Special Education Preschool Grants 84.287 ? Twenty-First Century Community Learning Centers 84.367 ? Supporting Effective Instruction State Grants 84.425C ? COVID-19 ? Governor?s Emergency Education Relief Fund 84.425D ? COVID-19 ? Elementary and Secondary Emergency Relief (ESSER) Fund 84.425R ? COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) 84.425U ? COVID-19 ? American Rescue Plan ? Elementary and Secondary Emergency Relief (ARP ESSER) Federal Award Number: H027A180073 (Year: 2019), H027A190073 (Year: 2020), H027A200073 (Year: 2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A180081 (Year: 2019), H173A190081 (Year: 2020), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022), S287C1900010 (Year: 2020), S287C200010 (Year 2021), S287C210010 (Year: 2022), S367A190001 (Year: 2020), S367A20001 (Year: 2021), S367A210001 (Year: 2022), S425C200049 (Year: 2021), S425C210049 (Year: 2021), S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425R210034 (Year: 2021), S425U210012-21A (Year: 2021) Questioned Costs: None Identified Description: The Georgia Department of Education should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Special Education Cluster, which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). Special Education Cluster funding is available to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities. The Twenty-First Century Community Learning Centers (21st CCLC) program was created by the Elementary and Secondary Education Act of 1965 to establish or expand community learning centers that provide students with academic enrichment opportunities during non-school hours or periods when school is not in session. These community learning centers provide services to support student learning and development, including tutoring and mentoring, homework help, academic enrichment, community service opportunities, and music, arts, sports, and cultural activities. The Supporting Effective Instruction State Grants (Title II, Part A) program was created by the Elementary and Secondary Education Act of 1965 to provide funds to state educational agencies and local educational agencies to increase student achievement consistent with the challenging state academic standards; improve the quality and effectiveness of teachers, principals, and other school leaders; increase the number of teachers, principals, and other school leaders who are effective in improving student academic achievement in schools; and provide low-income and minority students greater access to effective teachers, principals, and other school leaders. The Education Stabilization Fund (ESF) was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. Various ESF subprograms were created and allotted funding through COVID-19-related legislation. Many of these subprograms were designed to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. These subprograms include the Elementary and Secondary School Emergency Relief (ESSER) Fund, American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER), and Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public School (CRRSA EANS) programs. Additionally, elementary and secondary schools were allotted funding through the Governor?s Emergency Education Relief (GEER) Fund, which allocated resources to governors to provide emergency assistance to education-related-entities. Funds associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF subprograms are provided to the Georgia Department of Education (GaDOE) for allocation to eligible subrecipients. Because the GaDOE subgrants program funds to various entities, the GaDOE must perform certain monitoring activities related to these subrecipients. Criteria: As a recipient of federal awards, the GaDOE is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that ?All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes? [required] information at the time of the subaward? (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through monitoring of the subrecipient must include? (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the passthrough entity? (f) Verify that every subrecipient is audited as required by Subpart F ? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth? (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement against noncompliant subrecipients.? Condition: Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: ? A sample of 23 subrecipients associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF program was randomly selected for testing using a non-statistical sampling method. Auditors examined documentation to determine if the GaDOE had reviewed the results of each subrecipient?s audits appropriately; however, this testing revealed that one of the audits was not obtained or reviewed by the GaDOE as required. Additionally, the GaDOE could not provide documentation that the results of this audit were considered in the risk assessment process and followed up on to ensure that the subrecipient took appropriate and timely action to correct any deficiencies noted in the audit. ? A sample of seven subrecipients associated with the 21st CCLC program was selected for testing using a non-statistical sampling method. Auditors reviewed documentation to determine if appropriate monitoring was conducted over these subrecipients in accordance with the GaDOE?s internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one subrecipient tested. ? A sample of 23 subawards related to the Special Education Cluster was randomly selected for testing using a non-statistical sampling method. These subawards were reviewed to determine if all required components were included; however, this testing revealed that the subrecipient?s unique entity identifier was omitted from the subaward document in three instances. Cause: The GaDOE stated that the responsibility for maintaining documentation for audits of non-profit subrecipients was shifted to a new department due to the elimination of positions during the pandemic and was inadvertently overlooked. Additionally, the GaDOE stated that though other monitoring activities associated with the 21st CCLC program were performed, cross-functional monitoring and a site visit was not performed due to the fact that it was the last year that this particular subrecipient would be funded. Furthermore, the spreadsheet used to accumulate all subrecipient information did not include the UEI for three subrecipients due to the fact that the UEI requirement was recently implemented and the GaDOE experienced difficulty in obtaining the numbers. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal funds being expended for unallowable purposes, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the GaDOE: ? Follow established policies and procedures to ensure that subrecipients receive audits when necessary, the results of these audits are considered in the risk assessment process, and timely management decisions are made for any audit findings pertaining to federal awards; ? Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements; and ? Update the spreadsheet used to accumulate all subrecipient information to ensure that all subaward documents include the required components reflected within the Uniform Guidance. Views of Responsible Officials: We concur with this finding. We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs LEA audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st CCLC Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators.
2022-010 Improve Controls over Subrecipient Monitoring Compliance Requirement: Subrecipient Monitoring Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: None AL Number and Title: 84.027 ? Special Education Grants to States 84.173 ? Special Education Preschool Grants 84.287 ? Twenty-First Century Community Learning Centers 84.367 ? Supporting Effective Instruction State Grants 84.425C ? COVID-19 ? Governor?s Emergency Education Relief Fund 84.425D ? COVID-19 ? Elementary and Secondary Emergency Relief (ESSER) Fund 84.425R ? COVID-19 ? Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public Schools (CRRSA EANS) 84.425U ? COVID-19 ? American Rescue Plan ? Elementary and Secondary Emergency Relief (ARP ESSER) Federal Award Number: H027A180073 (Year: 2019), H027A190073 (Year: 2020), H027A200073 (Year: 2021), H027A210073 (Year: 2022), H027X210073 (Year: 2022), H173A180081 (Year: 2019), H173A190081 (Year: 2020), H173A200081 (Year: 2021), H173A210081 (Year: 2022), H173X210081 (Year: 2022), S287C1900010 (Year: 2020), S287C200010 (Year 2021), S287C210010 (Year: 2022), S367A190001 (Year: 2020), S367A20001 (Year: 2021), S367A210001 (Year: 2022), S425C200049 (Year: 2021), S425C210049 (Year: 2021), S425D200012 (Year: 2020), S425D210012 (Year: 2021), S425R210034 (Year: 2021), S425U210012-21A (Year: 2021) Questioned Costs: None Identified Description: The Georgia Department of Education should improve internal controls to ensure that required subrecipient monitoring activities are performed appropriately. Background Information: The Special Education Cluster, which is comprised of the Special Education Grants to States (IDEA, Part B) and Special Education Preschool Grants (IDEA Preschool) programs, was created by the Individuals with Disabilities Education Act (IDEA). Special Education Cluster funding is available to ensure that all children with disabilities have available to them a free appropriate public education that emphasizes special education and related services designed to meet their unique needs and prepares them for further education, employment, and independent living; ensure that the rights of children with disabilities and their parents are protected; assist states, localities, educational service agencies, and federal agencies to provide for the education of all children with disabilities; and assess and ensure the effectiveness of efforts to educate children with disabilities. The Twenty-First Century Community Learning Centers (21st CCLC) program was created by the Elementary and Secondary Education Act of 1965 to establish or expand community learning centers that provide students with academic enrichment opportunities during non-school hours or periods when school is not in session. These community learning centers provide services to support student learning and development, including tutoring and mentoring, homework help, academic enrichment, community service opportunities, and music, arts, sports, and cultural activities. The Supporting Effective Instruction State Grants (Title II, Part A) program was created by the Elementary and Secondary Education Act of 1965 to provide funds to state educational agencies and local educational agencies to increase student achievement consistent with the challenging state academic standards; improve the quality and effectiveness of teachers, principals, and other school leaders; increase the number of teachers, principals, and other school leaders who are effective in improving student academic achievement in schools; and provide low-income and minority students greater access to effective teachers, principals, and other school leaders. The Education Stabilization Fund (ESF) was created by the Coronavirus Aid, Relief, and Economic Security (CARES) Act to provide financial resources to educational entities to prevent, prepare for, and respond to coronavirus. Various ESF subprograms were created and allotted funding through COVID-19-related legislation. Many of these subprograms were designed to address the impact that COVID-19 has had, and continues to have, on elementary and secondary schools across the nation. These subprograms include the Elementary and Secondary School Emergency Relief (ESSER) Fund, American Rescue Plan ? Elementary and Secondary School Emergency Relief (ARP ESSER), and Coronavirus Response and Relief Supplemental Appropriations Act, 2021 ? Emergency Assistance to Non-Public School (CRRSA EANS) programs. Additionally, elementary and secondary schools were allotted funding through the Governor?s Emergency Education Relief (GEER) Fund, which allocated resources to governors to provide emergency assistance to education-related-entities. Funds associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF subprograms are provided to the Georgia Department of Education (GaDOE) for allocation to eligible subrecipients. Because the GaDOE subgrants program funds to various entities, the GaDOE must perform certain monitoring activities related to these subrecipients. Criteria: As a recipient of federal awards, the GaDOE is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 ? Internal Controls. Additionally, provisions included in the Uniform Guidance, Section 200.332 establish requirements for pass-through entities and state in part that ?All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes? [required] information at the time of the subaward? (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through monitoring of the subrecipient must include? (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the passthrough entity? (f) Verify that every subrecipient is audited as required by Subpart F ? Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth? (g) Consider whether the results of the subrecipient?s audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity?s own records. (h) Consider taking enforcement against noncompliant subrecipients.? Condition: Upon performing testing over subrecipient monitoring, auditors noted the following deficiencies: ? A sample of 23 subrecipients associated with the Special Education Cluster, 21st CCLC program, Title II, Part A program, and ESF program was randomly selected for testing using a non-statistical sampling method. Auditors examined documentation to determine if the GaDOE had reviewed the results of each subrecipient?s audits appropriately; however, this testing revealed that one of the audits was not obtained or reviewed by the GaDOE as required. Additionally, the GaDOE could not provide documentation that the results of this audit were considered in the risk assessment process and followed up on to ensure that the subrecipient took appropriate and timely action to correct any deficiencies noted in the audit. ? A sample of seven subrecipients associated with the 21st CCLC program was selected for testing using a non-statistical sampling method. Auditors reviewed documentation to determine if appropriate monitoring was conducted over these subrecipients in accordance with the GaDOE?s internal policy and the Uniform Guidance; however, this testing revealed that proper monitoring activities were not conducted for one subrecipient tested. ? A sample of 23 subawards related to the Special Education Cluster was randomly selected for testing using a non-statistical sampling method. These subawards were reviewed to determine if all required components were included; however, this testing revealed that the subrecipient?s unique entity identifier was omitted from the subaward document in three instances. Cause: The GaDOE stated that the responsibility for maintaining documentation for audits of non-profit subrecipients was shifted to a new department due to the elimination of positions during the pandemic and was inadvertently overlooked. Additionally, the GaDOE stated that though other monitoring activities associated with the 21st CCLC program were performed, cross-functional monitoring and a site visit was not performed due to the fact that it was the last year that this particular subrecipient would be funded. Furthermore, the spreadsheet used to accumulate all subrecipient information did not include the UEI for three subrecipients due to the fact that the UEI requirement was recently implemented and the GaDOE experienced difficulty in obtaining the numbers. Effect: The subrecipient monitoring deficiencies resulted in noncompliance with federal regulations. Without effective subrecipient monitoring controls in place to ensure compliance with all applicable federal requirements, there is an increased risk of federal funds being expended for unallowable purposes, subrecipients not properly administering federal programs in accordance with federal statutes, regulations, and the terms and conditions of the subawards, and untimely detection and correction of noncompliance. Recommendation: We recommend that the GaDOE: ? Follow established policies and procedures to ensure that subrecipients receive audits when necessary, the results of these audits are considered in the risk assessment process, and timely management decisions are made for any audit findings pertaining to federal awards; ? Follow established policies and procedures for monitoring of subrecipients to ensure proper accountability and compliance program requirements; and ? Update the spreadsheet used to accumulate all subrecipient information to ensure that all subaward documents include the required components reflected within the Uniform Guidance. Views of Responsible Officials: We concur with this finding. We have transitioned the subrecipient audit monitoring process to the Financial Review team within GaDOE which currently performs LEA audit monitoring. The controls already in place for the Financial Review team?s LEA audit monitoring will be duplicated for nonprofit audit monitoring to ensure all required procedures are complete and timely. Additionally, we will review the Division of Federal Programs Handbook, the 21st CCLC Subgrantee Manual, and the 21st CCLC Internal Operations manual to ensure compliance to the Uniform Grants Guidance for subrecipient monitoring. Where needed, language will be added to each manual to clarify and emphasize that subrecipient monitoring includes application review, budget review, drawdown approval, completion report review in addition to virtual or onsite monitoring of specific program indicators. The 21st CCLC documents will be updated to ensure a clear subrecipient monitoring process is established for the final year of a cohort. This process will clarify that subrecipient monitoring during the last funded year will include application review, budget review, drawdown approval, and completion report review. Additionally, LEAs identified as ?high-risk? will have an onsite or virtual monitoring on specific 21st CCLC indicators.