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.
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.
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: 2022-010 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grant Assistance Listing Number: 14.228 Award Number and Year: B-20-DW-50-0001 (2020) B-20-DC-50-0001 (2020) B-21-DC-50-0001 (2021) Compliance Requirement: Subrecipient Monitoring Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. 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 State of Vermont Agency of Commerce and Community Development was not able to provide support that it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in three of eight subrecipients selected for testing: ? For three of eight subrecipients, the Agency was unable to provide support that it ensured the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The Agency did not establish effective internal controls and procedures over subrecipient monitoring to ensure that it issued and monitored subawards in accordance with 2 CFR section 200.332. Effect: Failure to ensure subrecipients have obtained audits as required by Subpart F increases the risk that subrecipients may inappropriately spend and/or inaccurately track and report federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, or corrected on a timely basis. Questioned costs: Undetermined Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that an evaluation of independent audits is performed. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-021 Prior Year Finding: No Federal Agency: Department of the Treasury State Agency: Agency of Administration Federal Program: COVID-19 ? Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: SLFRP4407 (3/1/2021 ? 12/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?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 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)(iii) Federal Award Identification Number (FAIN); 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: Required federal award information was omitted from a subaward issued from the program. Context: The Agency of Administration (Agency) has oversight responsibility for Coronavirus State and Local Fiscal Recovery Funds expenditures and reporting for the State of Vermont (the State). Multiple agencies and departments within the State incur costs and issue subawards charged to the program. Twelve subrecipients were selected for testing and the Department of Public Service (Department) issued a subaward to 1 of the 12 subrecipients. The Federal Award Identification Number (FAIN) was not included on this subaward. Cause: The Department did not establish effective internal controls and procedures over subrecipient monitoring. It was unable to ensure that it provided all required information to its subrecipients upon award issuance. The Agency?s oversight of the program did not detect the error. Effect: Excluding the required federal grant award information at the time of subaward issuance 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. Questioned costs: Undetermined. Recommendation: We recommend the Agency work with the Department to review and enhance internal controls and procedures to ensure that all required federal award information is included in subawards. We further recommend that the Agency review its oversight procedures and controls to ensure that all State agencies and departments that issue subawards under the program are in compliance with federal requirements. Views of responsible officials: Management agrees with the finding.
Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health 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. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. 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. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).
Reference Number: 2022-004 Federal Program Title: HIV Prevention Activities Health Department Based Federal Assistance Listing Number: 93.940 Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: N/A Federal Award Number and Year: 5 NU62PS924619-02-00, 5 NU62SP924619-03-00, 5 NU62PS924569-04-00, 6 NU62PS924569-05-03; Fiscal Year 2021-22 Name of Department: Department of Public Health 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. Condition During our audit of the HIV Prevention Activities Health Department Based program, we selected nine (9) subrecipients with active contracts with the Department of Public Health (DPH) during FY 2021-22 and noted that one or more of the required elements defined in 2 CFR ?200.332 (a)(1) were not included for one (1) subrecipient. Cause It was an oversight that DPH did not communicate and inform one of its subrecipients about their subaward. 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. Questioned Costs Questioned costs were not determinable. Context For the nine (9) subrecipients selected for testing, which totaled $3,920,284 from a population of fifty-two (52) subrecipients with expenditures totaling $7,279,260, DPH did not communicate all of the required subaward data elements for one (1) subrecipient. The sample was not a statistically valid sample. Recommendation We recommend that for the subrecipient that was not provided the required elements, DPH provide a letter or amended agreement to include all the required elements of 2 CFR ?200.332(a).
See Schedule of Findings and Questioned Costs for chart/table. Condition During our audit, we examined a non statistical sample of three subawards and noted untimely evaluation of the subrecipients? risk of noncompliance for two subawards. Criteria 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect Without evaluating the subrecipient?s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not be providing the appropriate level of monitoring over its subrecipients. Cause and View of Responsible Officials Due to resource constraints in Office of Federal Awards Management (OFAM), the program personnel were unable to perform the subrecipients? risk of noncompliance in a timely manner. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200 which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State?s responsibilities as a pass-through entity are fulfilled, including a formal analysis of each subrecipient?s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following: The subrecipient?s prior experience with the same or similar subawards; The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; Whether the subrecipient has new personnel or new or substantially changed systems; and The extent and results of federal awarding agency monitoring.
See Schedule of Findings and Questioned Costs for chart/table. Condition During our audit, we examined a non statistical sample of two subawards and found no evidence of evaluation of the subrecipients? risk of noncompliance at the time of the subawards. Criteria 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect Without evaluating the subrecipient?s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not be providing the appropriate level of monitoring over its subrecipients. Cause and View of Responsible Officials Due to resource constraints in OFAM, the program personnel were unable to perform the subrecipients? risk of noncompliance in a timely manner. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200 which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State?s responsibilities as a pass-through entity are fulfilled, including a formal analysis of each subrecipient?s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following: The subrecipient?s prior experience with the same or similar subawards; The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; Whether the subrecipient has new personnel or new or substantially changed systems; and The extent and results of federal awarding agency monitoring.
See Schedule of Findings and Questioned Costs for chart/table. Condition During our audit, we examined a non statistical sample of seven subawards and found no evidence of evaluation of the subrecipients? risk of noncompliance at the time of the subaward for one of the subawards tested. Criteria 2 CFR Section 200.332(b) requires a pass-through entity to evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Effect Without evaluating the subrecipient?s risk of noncompliance and determining the appropriate subrecipient monitoring procedures necessary, the State may not be providing the appropriate level of monitoring over its subrecipients. Cause and View of Responsible Officials Due to resource constraints within OFAM, program personnel were unable to perform the subrecipient?s risk of noncompliance in a timely matter. Recommendation We recommend that program management ensure that program personnel are familiar with all grant requirements, including compliance with 2 CFR Part 200, which requires the reporting of all necessary federal award information to subrecipients and risk assessments of subrecipients. Management should develop procedures that ensure the State department?s responsibilities as a pass-through entity are fulfilled, including a formal analysis of each subrecipient?s risk of noncompliance with each of the respective subaward requirements. This evaluation of risk may include consideration of such factors as the following: The subrecipient?s prior experience with the same or similar subawards; The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; Whether the subrecipient has new personnel or new or substantially changed systems; and The extent and results of federal awarding agency monitoring.
The Warren County Fiscal Court Failed To Implement Adequate Internal Controls Over Subrecipient Monitoring Federal Program: 21.027 COVID-19 - Coronavirus State And Local Fiscal Recovery Funds Award Number and Year: 1505-0271 2021 Name of Federal Agency and Pass-Thru Agency (if applicable): U.S. Department of the Treasury Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Amount of Questioned Costs: None Opinion Modification (if applicable): Yes, Qualified COVID Related: Yes The Warren County Fiscal Court failed to implement adequate internal controls over subrecipient monitoring. The fiscal court granted a subaward of Coronavirus State And Local Fiscal Recovery Funds to Live the Dream Development, Inc. in the amount of $1,000,000 for an affordable housing project. As a requirement of the subaward, the subrecipient is required to submit quarterly progress and financial reports to the fiscal court. The fiscal court did not receive any quarterly subrecipient progress or financial reports during the 2021-2022 fiscal year. Awards unspent as of December 31, 2024 are required to be returned to the Warren County Fiscal Court. The award of $1,000,000 was paid on February 14, 2022. Subrecipient reports were not submitted by the subrecipient for quarters ending on March 31, 2022 or June 30, 2022. This was caused by an oversight of the fiscal court. The county treasurer was unaware that reports needed to be submitted to the fiscal court even if none of the funds have been spent by the subrecipient. The treasurer was under the assumption that the project had not been started as of June 30, 2022. By not receiving adequate subrecipient monitoring documentation, the fiscal court is unable to document their supervision of the subaward to the agency to ensure requirements for the federal monies are being followed. Additionally, unallowable activities could go unnoticed due to the lack of oversight. In addition, the opinion was modified. 2 CFR 200.332 lists the requirements for pass-through entities. 2 CFR 220.332(d) requires all pass-through entities to ?Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity.? Additionally, 2 CFR 200.501(a) states ?A non-federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single or program-specific audit conducted for that year in accordance with the provisions of this part.? This is not a repeat finding from the previous year.
2022 ? 001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus Relief Fund Assistance Listing Number: 21.019 Federal Award Identification Number and Year: SLT0198 Pass-Through Agency: County of Los Angeles Pass-Through Number: Unknown Award Period: March 1, 2020 through December 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: A pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: ? Reviewing financial and programmatic (performance and special reports) required by the PTE. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. ? Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition: During our testing, we noted LAHSA did not have adequate internal controls designed to properly monitor its? subrecipients. Questioned costs: Unable to determine. Context: During our testing of subrecipient monitoring, it was noted that LAHSA did not monitor 1 out of 8 subrecipients tested. The subrecipient received $169,035 for the fiscal year ended June 30, 2022. Cause: LAHSA's new subrecipient monitoring process was not implemented until January 2022. At that time, the subrecipients that were not monitored did not have an active contract with federal funding. As such, they were deemed to be low risk. LAHSA does not have a policy in place to ensure that the subrecipient monitoring plan and risk assessment is revisited throughout the year to ensure new contracts are assessed and monitored appropriately. Effect: LAHSA did not perform required monitoring over subrecipients of federal funding. The lack of internal controls over this compliance requirement provides an opportunity for noncompliance by subrecipients of the grant. Repeat Finding: Yes. Recommendation: We recommend LAHSA implements controls to ensure that the subrecipient monitoring plan is revisited at the time contracts are entered into in order to ensure proper coverage. Views of responsible officials: There is no disagreement with the audit finding.
2022-024 Oregon Housing and Community Services Subrecipients need to be monitored to ensure compliance with procurement standards Federal Awarding Agency: U.S. Department of Housing and Urban Development Assistance Listing Number and Name: 14.231 Emergency Solutions Grants Program (COVID-19) Federal Award Numbers and Years: E-20-DW-41-0001, 2020 (COVID-19) Compliance Requirement: Procurement, and Suspension and Debarment Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.317 - .327; 2 CFR 200.332(d) Federal regulations state that non-federal entities, including subrecipients, are required to have and use procurement procedures consistent with state and local laws and regulations and that conform to the federal procurement standards identified in 2 CFR 200.317 - .327. Pass-through entities, like the department, are required to monitor subrecipients for compliance with federal regulations and the terms and conditions of the award. Inquiries and testing determined the department?s fiscal monitoring procedures, which normally include review of compliance with procurement standards, were not fully performed during the fiscal year and only 6 of 45 subrecipients were reviewed. As a result, subrecipients could be out of compliance with procurement requirements. We recommend the department ensure subrecipients are monitored for compliance with procurement requirements.
2022-063 Oregon Department of Transportation Consistency needed when providing required federal award information to subrecipients Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332(a)(1) Federal regulations require pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required information. We examined 17 subrecipient awards to ensure the information required under 2 CFR 200.332(a)(1) was communicated at the time of the subaward. Each award examined was missing one or more of the required elements: ? 15 samples did not include the subrecipient?s Unique Entity Identifier or DUNS number; ? 7 samples did not provide the Federal Award Identification Number (FAIN); ? 5 samples did not provide the Federal Award date; and ? 1 sample did not provide the correct assistance listing number. The required award information is necessary for the subrecipient to accurately report the subaward information in its accounting records and on the schedule of expenditure of federal awards. Procedures to communicate award information are not consistently followed across the department and as a result do not ensure that all the required award information is communicated. Specifically, some required information is included in the Federal Project Agreement from the Federal Management Information System (FMIS), but not all managers were aware it needed to be provided. In many cases an exhibit was included with the agreement that could have provided all the required information, but the exhibit was not completed. We recommend the department adopt procedures for preparing subaward agreements that ensure all required information is provided to subrecipients at the time of the subaward.
2022-063 Oregon Department of Transportation Consistency needed when providing required federal award information to subrecipients Federal Awarding Agency: U.S. Department of Transportation Assistance Listing Number and Name: 20.205 Highway Planning and Construction Federal Award Numbers and Years: Various Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency, Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332(a)(1) Federal regulations require pass-through entities to ensure every subaward is clearly identified to the subrecipient as a subaward and includes certain required information. We examined 17 subrecipient awards to ensure the information required under 2 CFR 200.332(a)(1) was communicated at the time of the subaward. Each award examined was missing one or more of the required elements: ? 15 samples did not include the subrecipient?s Unique Entity Identifier or DUNS number; ? 7 samples did not provide the Federal Award Identification Number (FAIN); ? 5 samples did not provide the Federal Award date; and ? 1 sample did not provide the correct assistance listing number. The required award information is necessary for the subrecipient to accurately report the subaward information in its accounting records and on the schedule of expenditure of federal awards. Procedures to communicate award information are not consistently followed across the department and as a result do not ensure that all the required award information is communicated. Specifically, some required information is included in the Federal Project Agreement from the Federal Management Information System (FMIS), but not all managers were aware it needed to be provided. In many cases an exhibit was included with the agreement that could have provided all the required information, but the exhibit was not completed. We recommend the department adopt procedures for preparing subaward agreements that ensure all required information is provided to subrecipients at the time of the subaward.
2022-025 Oregon Housing and Community Services Perform fiscal monitoring for subrecipients administrative expenditures to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $121,463 (known) (COVID-19) Criteria: 2 CFR 200.332(a)(5) and (d) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and in compliance with federal requirements. Additionally, department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is in compliance with program requirements. The department passed through program funds to community action agencies (subrecipients) to provide program delivery, including administrative costs. The department performed fiscal monitoring for only five of their 18 subrecipients during the audit period due to staff turnover. Fiscal monitoring includes procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. Due to the limited fiscal monitoring performed, auditors performed additional procedures at the subrecipient level to determine whether the department was compliant with program requirements. We tested a total of 82 transactions, 70 randomly selected and 12 judgmentally selected from the 13 subrecipients that did not receive subrecipient monitoring during the fiscal year. We noted the following: ? One subrecipient did not respond to audit requests for documentation, resulting in an inability to test four transactions totaling $4,114. ? One subrecipient did not provide sufficiently detailed documentation to determine whether 7 transactions were for accurate amounts totaling $117,349. Of those seven transactions, we were unable to determine whether two transactions were for allowable activities or appropriately categorized as administrative expenditures. Without adequate monitoring of subrecipients, the department?s ability to ensure compliance with program requirements is diminished. We recommend department management perform fiscal monitoring to ensure subrecipients are expending administrative funds in accordance with program requirements.
2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Eligibility Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $21,624 (known); $11,067,350 (likely) (COVID-19) Criteria: 2 CFR 200.332(d); 2 CFR 200.501(g) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and are compliant with federal requirements. Additionally, department management is responsible for ensuring compliance when a contractor is responsible for program compliance or the contractor?s records must be reviewed to determine program compliance. The department provided $140 million and $46 million of phase one program funds to community action agencies (subrecipients) and a third-party vendor (contractor) to provide program delivery, respectively; and $132 million phase two program funds to only the contractor. Program delivery included determining client eligibility and making payments for direct client assistance for rent, utilities, internet, and other housing related costs. During implementation of the program, the department provided program manuals to the subrecipients and contractor. Due to the department?s limited staff, they focused on updating policies and procedures to address systemic issues identified; however, if a particularly challenging application required the department?s review, they were available to provide direct assistance. The department did not implement any predefined, systemic program monitoring of the subrecipients or contractor to ensure direct client assistance payments were paid to only eligible clients for only allowable and supported amounts. Therefore, auditors performed additional procedures at the subrecipient and contractor level to determine whether direct client assistance payments were paid to eligible clients for allowable activities. We tested a total of 62 randomly selected direct client assistance payments at 16 subrecipients totaling $183,515, and found the following: ? One subrecipient did not respond to audit requests for documentation, resulting in an inability to test one transaction in the amount of $360. ? One subrecipient did not obtain documentation to support that there was a lease agreement in place, resulting in questioned costs of $5,775. When extrapolated to the total population, these errors result in over $2.3 million in likely questioned costs. We tested 61 randomly selected contractor direct client assistance payments totaling $374,274, and found the following: ? One payment where an incorrect landlord was paid in the amount of $2,700. Attempts to recover the funds have been unsuccessful as of the date of the finding. ? Two payments where the rental amount was doubled, resulting in overpayments totaling $5,910. ? Seven payments where amounts already paid were not accurately reflected in the calculation of assistance provided, resulting in overpayments totaling $4,191. ? Three payments where amounts did not agree to supporting documentation, resulting in overpayments of $2,181. ? Three payments where there was insufficient documentation for amounts paid, resulting in overpayments of $432. ? One payment where costs were paid for the same household on alternate applications, resulting in an overpayment of $73. When extrapolated to the total population, these errors result in over $8.7 million in likely questioned costs. We recommend department management implement predefined, systemic program monitoring to ensure the subrecipients and contractor are administering program funds in accordance with program requirements.
2022-029 Oregon Housing and Community Services Ensure accessible documentation to evidence compliance with program requirements Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Eligibility Type of Finding: Material Weakness Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.302(a); 2 CFR 200.332(a)(5) Department management is responsible for communicating to subrecipients that they are required to permit the department and auditors access to their records as necessary to ensure the department is compliant with program requirements. To ensure compliance with program requirements, subrecipient records must also be sufficiently detailed. The department passed through $140 million phase one program funds to community action agencies (subrecipients) to provide program delivery. The department performed limited fiscal monitoring during the audit period which included procedures to address compliance with activities allowed and allowable cost requirements for administrative costs. The department did not perform any program monitoring during the audit period which primarily addresses compliance with eligibility requirements. To determine whether the department complied with program requirements for the fiscal year, auditors attempted to reconcile detailed subrecipient ledgers with the intent of selecting and testing sample items at each individual subrecipient organization. We noted issues with two individual subrecipients, resulting in an inability to perform testing procedures over a total of $21,438,521 in program expenditures. For the first subrecipient we were able to reconcile their detailed ledgers to the department?s financial records, however their detailed ledger included pass-through payments to a third organization for program delivery. As a result of the combination of direct and pass-through payments, we were unable to obtain sufficiently detailed data that also reconciled to the department?s financial records to select individual transactions for testing. This subrecipient represents $19,877,962 of the unaudited expenditures. For the second subrecipient we were able to reconcile their detailed ledgers to the department?s financial records and select administrative and program transactions for testing. However, the subrecipient was unresponsive to documentation requests to substantiate expenditures. This subrecipient accounted for $1,560,559 of the unaudited expenditures. We recommend department management obtain and reconcile sufficiently detailed subrecipient ledgers and support to substantiate expenditures to allow for fiscal and program monitoring to ensure subrecipients are administering program funds in accordance with program requirements.
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary.
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary.
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary.
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary.