FINDING 2022-206The Department did not complete required subrecipient monitoring of the Elementary and Secondary School Emergency Relief (ESSER) Fund of the Education Stabilization Fund.Type of Finding: Material Noncompliance, Material WeaknessAssistance Listing Title: Elementary and Secondary School Emergency Relief Fund; Emergency Assistance for Non-Public Schools; ARPA ESSER III; ARPA ESSER - Homeless Children and YouthAssistance Listing Number: 84.425D; 84.425R; 84.425U; 84.425WFederal Award Number: S425D210043; S425D200043; S425R210024; S425U210043; S425W210013Program Year: January 5, 2021 ? September 30, 2023; May 18, 2020 ? September 30, 2022; February 11, 2021 ? September 30, 2023; March 24, 2021 ? September 30, 2024; April 23, 2021 ? September 30, 2024Federal Agency: Department of EducationCompliance Requirement: Subrecipient MonitoringQuestioned Costs: NoneCriteria: The U.S. Code of Federal Regulations (CFR) 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, superseding the Office of Management and Budget (OMB) Circular A-102, Grants and Cooperative Agreements with State and Local Governments, describes the pass-through entity?s responsibility for administering necessary requirements on subrecipients so that the federal award is used in accordance with federal regulations.Specifically, 2 CFR 200.332(d) and 2 CFR 25.200 identify the requirements for the Department as the pass- through entity in providing subawards. This includes communication of certain information, such as the subrecipient?s unique entity identifier and required registration in the System for Award Management (SAM). In addition, the Department must evaluate each subrecipient?s risk of noncompliance with federal statutes and the terms and conditions of the subaward when determining the extent of subrecipient monitoring to be completed to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward, and that the subaward performance goals are achieved. 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, monitoring must include a review of financial and performance reports required by the pass-through entity, follow up on any deficiencies identified in the subrecipient that are detected through audits, on-site reviews and other means, and issuing a management decision for audit findings, as required by 2 CFR 200.521.Finally, 2 CFR 200.303 requires the Department to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Department is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award.Condition: The Department initially received ESSER funding in fiscal year 2021 and integrated ESSER monitoring with the general subrecipient monitoring used for other federal programs. The Department?s 2020- 2021 Monitoring Tool included only one indicator related to the ESSER program and did not adequately address all subrecipient monitoring requirements. However, in fiscal year 2021, the Department determined that the existing monitoring procedures were not robust enough for the additional requirements associated with ESSER subrecipient monitoring and discontinued those procedures without implementing any alternative procedures during fiscal year 2022.This was a finding included in the Single Audit Report for the year ended June 30, 2021, and the Department provided a corrective action plan to monitor subrecipients. However, the Department did not implement the plan until after the audit period, in fiscal year 2023.Cause: The Department realized the current procedures were not sufficient to meet the monitoring requirements of ESSER and indicated a monitoring process specific to the ESSER program compliance requirements was being developed; however, it was not developed in a timely manner to comply with federal requirements.Effect: The Department is not in compliance with subrecipient monitoring requirements. Without adequate monitoring of subrecipients, the Department is exposed to an increased risk of making improper payments for unallowable or unsupported costs.Recommendation: We recommend that the Department implement procedures to ensure compliance with all requirements as a pass-through entity. We also recommend that the Department design and implement effective control procedures to ensure subrecipient monitoring activities are complete and appropriate.Management?s View: The Department agrees with this finding.Corrective Action: It was not until the end of the 2022 legislative session that spending authority was given to the State Department of Education to use ARP ESSER administrative funds to hire additional staff to meet the robust requirements identified by the U.S. Department of Education. Up to that point, only one full-time person was handling all of the needs associated with ESSER funds. Since then, two positions have been hired. The ESSER Data and Reporting Coordinator began in April 2022, and the ESSER Monitoring Coordinator began in June 2022. While developing the monitoring procedures began in July 2022, it was after the audit timeframe. The Department now has in place all ESSER monitoring policies and procedures and will complete year one monitoring before May 5, 2023.Auditor?s Concluding Remarks: We thank the Department for its cooperation and assistance throughout the audit.
2022-007 - Noncompliance with Subrecipient Monitoring RequirementsAward Years: 2018, 2020 - 2022Award Numbers: DUE-2044358, NA18OAR4170098, OIA-2019511, OIA-2119688Compliance Requirement: Subrecipient MonitoringRepeat Finding: Yes (Prior Year Finding No. 2021-010)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the second consecutive year, UL Lafayette did not adequately monitor subrecipients of the R&D Cluster programs. In a non-statistical sample of five subawards out of a population of 49 subawards, it was noted that for four (80%) of the subrecipients evaluated UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards. Additionally, for all five (100%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria: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.Per 2 CFR 200.332(f), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient?s fiscal year.2 CFR 200.332(d)(2) requires that pass-through entities follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient from the pass-through entities detected through audits, on-site reviews, and written confirmation from the subrecipient.2 CFR 200.332(d)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient?s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings.Cause:UL Lafayette management indicated that it was working on internal procedures to adequately monitor subrecipients as result of the prior-year finding. However, management has yet to finalize and apply these procedures on all active subrecipients.Effect:Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency.Recommendation:UL Lafayette should strengthen controls to ensure the timely review of all required subrecipient audit reports in order to evaluate the impact of any findings noted in the audits and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations.Management?s Response and Corrective Action Plan:Management did not concur with the finding, noting it did not have sufficient time in fiscal year 2022 for corrective action and provided its progress on addressing the finding (B-83).
2022-011 - Inadequate Controls over and Noncompliance with Subrecipient Monitoring RequirementsAward Years: 2019 - 2021Award Numbers: AA332321955A22, AA347712055A22, AA363222155A22Compliance Requirements: Activities Allowed or Unallowed, Subrecipient MonitoringRepeat Finding: Yes (Prior Year Finding No. 2021-019)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the fourth consecutive year, the Louisiana Workforce Commission (LWC) did not adequately follow-up on subrecipient monitoring reports under the Workforce Innovation and Opportunity Act (WIOA) Cluster programs.Our review of LWC?s fiscal year 2022 monitoring reports, of fiscal year 2020, for all 15 of LWC?s subrecipients, disclosed the following:? Two monitoring reports were not issued timely by LWC. The monitoring reports were issued 74 and 75 days after the completion of the monitoring review. LWC?s policy requires monitoring review reports to be issued 60 days after the completion of the monitoring review.? For four monitoring reports, close out letters were issued 145 to 191 days after monitoring report issuance. For six monitoring reports, close out letters were not issued as of January 2023, while the monitoring reports for these reviews were issued more than 200 days prior. The monitoring reports include findings with possible questioned costs totaling $3.1 million. LWC policy does not specifically address timeliness requirements for close out letters.In a non-statistical random sample of five of 15 subrecipient working papers, we noted the following:? Three subrecipients had findings on the monitoring reports stemming from a lack of documentation supporting the subrecipients? drawdowns of WIOA funds, and drawdowns of federal funds could not be reconciled by LWC to the subrecipients accounting records. The monitoring reports noted potential questioned costs associated with these drawdowns. These reviews are included in the six monitoring reports not issued as of January 2023, noted in the bullet above. Timely resolution would allow LWC to quickly address any compliance issues at the subrecipient level. According to LWC, it is working with the subrecipients to reconcile the federal funds drawdowns and close out the reports.Criteria:2 CFR 200.332(d) requires that pass-through entities 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 200.332(d)(2) requires that pass-through entities follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient from the pass-through entities detected through reviews.Annual monitoring reviews are required on all subrecipients for compliance with federal requirements. The review includes a review of LWC federal drawdowns for subrecipient expenditures. LWC fiscal relies on the monitoring section to review the drawdown documentation at the subrecipient to ensure that drawdowns are adequately supported.20 CFR 683.410 requires pass-through entities to issue management decisions (reports) on applicable findings and follow-up to ensure subrecipients take prompt and appropriate action on all audit findings.LWC?s Policy Number OWD 4-12 requires monitoring reviews to be issued within 60 days of completion of the monitoring review.Cause:LWC did not follow established policy for timely issuance of monitoring reports. LWC policy does not specifically address timeliness requirements for issuing close out letters.Effect:Failure to timely resolve documentation and questioned costs impairs LWC?s ability to ensure that program funds passed through to its subrecipients were spent in accordance with program regulations and increases the risk of improper payments, which LWC may have to repay to the federal grantor. WIOA program expenditures totaled $56.5 million during state fiscal year 2022, with approximately $46 million provided to subrecipients.Recommendation:LWC management should ensure that subrecipient monitoring reports are issued in a timely manner in accordance with LWC policy. LWC management should develop and implement policy ensuring timely and adequate close out of monitoring reviews.Management?s Response and Corrective Action Plan:Management concurred in part with the finding and provided a corrective action plan (B-59).
2022-011 - Inadequate Controls over and Noncompliance with Subrecipient Monitoring RequirementsAward Years: 2019 - 2021Award Numbers: AA332321955A22, AA347712055A22, AA363222155A22Compliance Requirements: Activities Allowed or Unallowed, Subrecipient MonitoringRepeat Finding: Yes (Prior Year Finding No. 2021-019)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the fourth consecutive year, the Louisiana Workforce Commission (LWC) did not adequately follow-up on subrecipient monitoring reports under the Workforce Innovation and Opportunity Act (WIOA) Cluster programs.Our review of LWC?s fiscal year 2022 monitoring reports, of fiscal year 2020, for all 15 of LWC?s subrecipients, disclosed the following:? Two monitoring reports were not issued timely by LWC. The monitoring reports were issued 74 and 75 days after the completion of the monitoring review. LWC?s policy requires monitoring review reports to be issued 60 days after the completion of the monitoring review.? For four monitoring reports, close out letters were issued 145 to 191 days after monitoring report issuance. For six monitoring reports, close out letters were not issued as of January 2023, while the monitoring reports for these reviews were issued more than 200 days prior. The monitoring reports include findings with possible questioned costs totaling $3.1 million. LWC policy does not specifically address timeliness requirements for close out letters.In a non-statistical random sample of five of 15 subrecipient working papers, we noted the following:? Three subrecipients had findings on the monitoring reports stemming from a lack of documentation supporting the subrecipients? drawdowns of WIOA funds, and drawdowns of federal funds could not be reconciled by LWC to the subrecipients accounting records. The monitoring reports noted potential questioned costs associated with these drawdowns. These reviews are included in the six monitoring reports not issued as of January 2023, noted in the bullet above. Timely resolution would allow LWC to quickly address any compliance issues at the subrecipient level. According to LWC, it is working with the subrecipients to reconcile the federal funds drawdowns and close out the reports.Criteria:2 CFR 200.332(d) requires that pass-through entities 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 200.332(d)(2) requires that pass-through entities follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient from the pass-through entities detected through reviews.Annual monitoring reviews are required on all subrecipients for compliance with federal requirements. The review includes a review of LWC federal drawdowns for subrecipient expenditures. LWC fiscal relies on the monitoring section to review the drawdown documentation at the subrecipient to ensure that drawdowns are adequately supported.20 CFR 683.410 requires pass-through entities to issue management decisions (reports) on applicable findings and follow-up to ensure subrecipients take prompt and appropriate action on all audit findings.LWC?s Policy Number OWD 4-12 requires monitoring reviews to be issued within 60 days of completion of the monitoring review.Cause:LWC did not follow established policy for timely issuance of monitoring reports. LWC policy does not specifically address timeliness requirements for issuing close out letters.Effect:Failure to timely resolve documentation and questioned costs impairs LWC?s ability to ensure that program funds passed through to its subrecipients were spent in accordance with program regulations and increases the risk of improper payments, which LWC may have to repay to the federal grantor. WIOA program expenditures totaled $56.5 million during state fiscal year 2022, with approximately $46 million provided to subrecipients.Recommendation:LWC management should ensure that subrecipient monitoring reports are issued in a timely manner in accordance with LWC policy. LWC management should develop and implement policy ensuring timely and adequate close out of monitoring reviews.Management?s Response and Corrective Action Plan:Management concurred in part with the finding and provided a corrective action plan (B-59).
2022-011 - Inadequate Controls over and Noncompliance with Subrecipient Monitoring RequirementsAward Years: 2019 - 2021Award Numbers: AA332321955A22, AA347712055A22, AA363222155A22Compliance Requirements: Activities Allowed or Unallowed, Subrecipient MonitoringRepeat Finding: Yes (Prior Year Finding No. 2021-019)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the fourth consecutive year, the Louisiana Workforce Commission (LWC) did not adequately follow-up on subrecipient monitoring reports under the Workforce Innovation and Opportunity Act (WIOA) Cluster programs.Our review of LWC?s fiscal year 2022 monitoring reports, of fiscal year 2020, for all 15 of LWC?s subrecipients, disclosed the following:? Two monitoring reports were not issued timely by LWC. The monitoring reports were issued 74 and 75 days after the completion of the monitoring review. LWC?s policy requires monitoring review reports to be issued 60 days after the completion of the monitoring review.? For four monitoring reports, close out letters were issued 145 to 191 days after monitoring report issuance. For six monitoring reports, close out letters were not issued as of January 2023, while the monitoring reports for these reviews were issued more than 200 days prior. The monitoring reports include findings with possible questioned costs totaling $3.1 million. LWC policy does not specifically address timeliness requirements for close out letters.In a non-statistical random sample of five of 15 subrecipient working papers, we noted the following:? Three subrecipients had findings on the monitoring reports stemming from a lack of documentation supporting the subrecipients? drawdowns of WIOA funds, and drawdowns of federal funds could not be reconciled by LWC to the subrecipients accounting records. The monitoring reports noted potential questioned costs associated with these drawdowns. These reviews are included in the six monitoring reports not issued as of January 2023, noted in the bullet above. Timely resolution would allow LWC to quickly address any compliance issues at the subrecipient level. According to LWC, it is working with the subrecipients to reconcile the federal funds drawdowns and close out the reports.Criteria:2 CFR 200.332(d) requires that pass-through entities 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 200.332(d)(2) requires that pass-through entities follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient from the pass-through entities detected through reviews.Annual monitoring reviews are required on all subrecipients for compliance with federal requirements. The review includes a review of LWC federal drawdowns for subrecipient expenditures. LWC fiscal relies on the monitoring section to review the drawdown documentation at the subrecipient to ensure that drawdowns are adequately supported.20 CFR 683.410 requires pass-through entities to issue management decisions (reports) on applicable findings and follow-up to ensure subrecipients take prompt and appropriate action on all audit findings.LWC?s Policy Number OWD 4-12 requires monitoring reviews to be issued within 60 days of completion of the monitoring review.Cause:LWC did not follow established policy for timely issuance of monitoring reports. LWC policy does not specifically address timeliness requirements for issuing close out letters.Effect:Failure to timely resolve documentation and questioned costs impairs LWC?s ability to ensure that program funds passed through to its subrecipients were spent in accordance with program regulations and increases the risk of improper payments, which LWC may have to repay to the federal grantor. WIOA program expenditures totaled $56.5 million during state fiscal year 2022, with approximately $46 million provided to subrecipients.Recommendation:LWC management should ensure that subrecipient monitoring reports are issued in a timely manner in accordance with LWC policy. LWC management should develop and implement policy ensuring timely and adequate close out of monitoring reviews.Management?s Response and Corrective Action Plan:Management concurred in part with the finding and provided a corrective action plan (B-59).
2022-007 - Noncompliance with Subrecipient Monitoring RequirementsAward Years: 2018, 2020 - 2022Award Numbers: DUE-2044358, NA18OAR4170098, OIA-2019511, OIA-2119688Compliance Requirement: Subrecipient MonitoringRepeat Finding: Yes (Prior Year Finding No. 2021-010)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the second consecutive year, UL Lafayette did not adequately monitor subrecipients of the R&D Cluster programs. In a non-statistical sample of five subawards out of a population of 49 subawards, it was noted that for four (80%) of the subrecipients evaluated UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards. Additionally, for all five (100%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria: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.Per 2 CFR 200.332(f), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient?s fiscal year.2 CFR 200.332(d)(2) requires that pass-through entities follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient from the pass-through entities detected through audits, on-site reviews, and written confirmation from the subrecipient.2 CFR 200.332(d)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient?s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings.Cause:UL Lafayette management indicated that it was working on internal procedures to adequately monitor subrecipients as result of the prior-year finding. However, management has yet to finalize and apply these procedures on all active subrecipients.Effect:Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency.Recommendation:UL Lafayette should strengthen controls to ensure the timely review of all required subrecipient audit reports in order to evaluate the impact of any findings noted in the audits and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations.Management?s Response and Corrective Action Plan:Management did not concur with the finding, noting it did not have sufficient time in fiscal year 2022 for corrective action and provided its progress on addressing the finding (B-83).
2022-007 - Noncompliance with Subrecipient Monitoring RequirementsAward Years: 2018, 2020 - 2022Award Numbers: DUE-2044358, NA18OAR4170098, OIA-2019511, OIA-2119688Compliance Requirement: Subrecipient MonitoringRepeat Finding: Yes (Prior Year Finding No. 2021-010)See Schedule of Findings and Questioned Costs for chart/tableCondition:For the second consecutive year, UL Lafayette did not adequately monitor subrecipients of the R&D Cluster programs. In a non-statistical sample of five subawards out of a population of 49 subawards, it was noted that for four (80%) of the subrecipients evaluated UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards. Additionally, for all five (100%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria: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.Per 2 CFR 200.332(f), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient?s fiscal year.2 CFR 200.332(d)(2) requires that pass-through entities follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies provided to the subrecipient from the pass-through entities detected through audits, on-site reviews, and written confirmation from the subrecipient.2 CFR 200.332(d)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient?s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings.Cause:UL Lafayette management indicated that it was working on internal procedures to adequately monitor subrecipients as result of the prior-year finding. However, management has yet to finalize and apply these procedures on all active subrecipients.Effect:Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency.Recommendation:UL Lafayette should strengthen controls to ensure the timely review of all required subrecipient audit reports in order to evaluate the impact of any findings noted in the audits and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations.Management?s Response and Corrective Action Plan:Management did not concur with the finding, noting it did not have sufficient time in fiscal year 2022 for corrective action and provided its progress on addressing the finding (B-83).
2022-018 - Inadequate Controls over Subrecipient AgreementsAward Years: 2019 - 2022Award Numbers: 2201LATANF, B08TI083018-01, B08TI083450-01, B09SM082603-01, B09SM083804-01, H79SM083477, H79SP081004, H79TI081691, X06SM016019-19, X06SM083694-01Compliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Acadiana Area Human Services District (AAHSD) failed to comply with all regulations set forth by 2 CFR 200.332.AAHSD is allocated federal funds from the Louisiana Department of Health (LDH), Office of Behavioral Health (OBH) as interagency transfers, and AAHSD passes these funds to other entities via contracts to perform consulting, social, and professional services. The federal programs involved had awards totaling $3,895,985 and $6,108,836 allocated to AAHSD for fiscal years 2021 and 2022, respectively.We reviewed all 28 agreements identified by AAHSD as subrecipients and determined that for 18 (64%) of the subawards, AAHSD was unable to provide documentation of whether each subrecipient was required to obtain an audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for all 28 of the subrecipients, AAHSD could not provide evidence that the required risk assessment was performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria:Federal regulations require AAHSD, as the pass-through entity, to comply with 2 CFR 200.332 when subawards are made to subrecipients.Cause:AAHSD failed to develop adequate policies and procedures to ensure compliance with regulations set forth by 2 CFR 200.332 were performed timely.Effect:AAHSD or the subrecipient may not comply with the award and federal regulations.Recommendation:AAHSD management should strengthen its policies and procedures to ensure that regulations set forth by 2 CFR 200.332 are being addressed timely.Management?s Response and Corrective Action Plan:Management concurred with the finding and outlined a plan of corrective action (B-2).
2022-018 - Inadequate Controls over Subrecipient AgreementsAward Years: 2019 - 2022Award Numbers: 2201LATANF, B08TI083018-01, B08TI083450-01, B09SM082603-01, B09SM083804-01, H79SM083477, H79SP081004, H79TI081691, X06SM016019-19, X06SM083694-01Compliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Acadiana Area Human Services District (AAHSD) failed to comply with all regulations set forth by 2 CFR 200.332.AAHSD is allocated federal funds from the Louisiana Department of Health (LDH), Office of Behavioral Health (OBH) as interagency transfers, and AAHSD passes these funds to other entities via contracts to perform consulting, social, and professional services. The federal programs involved had awards totaling $3,895,985 and $6,108,836 allocated to AAHSD for fiscal years 2021 and 2022, respectively.We reviewed all 28 agreements identified by AAHSD as subrecipients and determined that for 18 (64%) of the subawards, AAHSD was unable to provide documentation of whether each subrecipient was required to obtain an audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for all 28 of the subrecipients, AAHSD could not provide evidence that the required risk assessment was performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria:Federal regulations require AAHSD, as the pass-through entity, to comply with 2 CFR 200.332 when subawards are made to subrecipients.Cause:AAHSD failed to develop adequate policies and procedures to ensure compliance with regulations set forth by 2 CFR 200.332 were performed timely.Effect:AAHSD or the subrecipient may not comply with the award and federal regulations.Recommendation:AAHSD management should strengthen its policies and procedures to ensure that regulations set forth by 2 CFR 200.332 are being addressed timely.Management?s Response and Corrective Action Plan:Management concurred with the finding and outlined a plan of corrective action (B-2).
2022-018 - Inadequate Controls over Subrecipient AgreementsAward Years: 2019 - 2022Award Numbers: 2201LATANF, B08TI083018-01, B08TI083450-01, B09SM082603-01, B09SM083804-01, H79SM083477, H79SP081004, H79TI081691, X06SM016019-19, X06SM083694-01Compliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Acadiana Area Human Services District (AAHSD) failed to comply with all regulations set forth by 2 CFR 200.332.AAHSD is allocated federal funds from the Louisiana Department of Health (LDH), Office of Behavioral Health (OBH) as interagency transfers, and AAHSD passes these funds to other entities via contracts to perform consulting, social, and professional services. The federal programs involved had awards totaling $3,895,985 and $6,108,836 allocated to AAHSD for fiscal years 2021 and 2022, respectively.We reviewed all 28 agreements identified by AAHSD as subrecipients and determined that for 18 (64%) of the subawards, AAHSD was unable to provide documentation of whether each subrecipient was required to obtain an audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for all 28 of the subrecipients, AAHSD could not provide evidence that the required risk assessment was performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria:Federal regulations require AAHSD, as the pass-through entity, to comply with 2 CFR 200.332 when subawards are made to subrecipients.Cause:AAHSD failed to develop adequate policies and procedures to ensure compliance with regulations set forth by 2 CFR 200.332 were performed timely.Effect:AAHSD or the subrecipient may not comply with the award and federal regulations.Recommendation:AAHSD management should strengthen its policies and procedures to ensure that regulations set forth by 2 CFR 200.332 are being addressed timely.Management?s Response and Corrective Action Plan:Management concurred with the finding and outlined a plan of corrective action (B-2).
2022-019 - Control Weakness Relating to Foster Care Subrecipient MonitoringAward Year: 2022Award Number: 2201LAFOSTCompliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Department of Children and Family Services (DCFS) did not adequately review subrecipient Foster Care Title IV-E (Foster Care) invoices submitted by the Department of Public Safety and Corrections ? Youth Services ? Office of Juvenile Justice (OJJ) for reimbursement of administrative expenditures to ensure billings were accurately calculated.During our procedures performed at OJJ, which was in addition to our testing conducted through sampling at DCFS, it came to our attention that on the administrative invoice for the quarter ending December 2021, there were errors due to OJJ using incorrect expenditure data, resulting in billing errors that were not detected by DCFS.Criteria:2 CFR 200.332(d) requires that pass-through entities monitor the activities of subrecipients as necessary to ensure that the subaward complies with the terms and conditions of the subaward.Per DCFS?s contract with OJJ related to the Foster Care program, DCFS agrees to receive, review, and certify expenditure reports for Foster Care expenditures.Cause:These conditions occurred because of a weakness in controls in monitoring Foster Care administrative invoices.Effect:Failure to properly review invoices resulted in an over reimbursement and could result in disallowed costs by the federal grantor. Based on the methodology used, there was $128,236 in overpayments considered questioned costs.Recommendation:DCFS should strengthen controls over review to ensure administrative invoices submitted by OJJ are calculated accurately.Management?s Response and Corrective Action Plan:Management concurred with the finding and provided a corrective action plan (B-5).
2022-018 - Inadequate Controls over Subrecipient AgreementsAward Years: 2019 - 2022Award Numbers: 2201LATANF, B08TI083018-01, B08TI083450-01, B09SM082603-01, B09SM083804-01, H79SM083477, H79SP081004, H79TI081691, X06SM016019-19, X06SM083694-01Compliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Acadiana Area Human Services District (AAHSD) failed to comply with all regulations set forth by 2 CFR 200.332.AAHSD is allocated federal funds from the Louisiana Department of Health (LDH), Office of Behavioral Health (OBH) as interagency transfers, and AAHSD passes these funds to other entities via contracts to perform consulting, social, and professional services. The federal programs involved had awards totaling $3,895,985 and $6,108,836 allocated to AAHSD for fiscal years 2021 and 2022, respectively.We reviewed all 28 agreements identified by AAHSD as subrecipients and determined that for 18 (64%) of the subawards, AAHSD was unable to provide documentation of whether each subrecipient was required to obtain an audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for all 28 of the subrecipients, AAHSD could not provide evidence that the required risk assessment was performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria:Federal regulations require AAHSD, as the pass-through entity, to comply with 2 CFR 200.332 when subawards are made to subrecipients.Cause:AAHSD failed to develop adequate policies and procedures to ensure compliance with regulations set forth by 2 CFR 200.332 were performed timely.Effect:AAHSD or the subrecipient may not comply with the award and federal regulations.Recommendation:AAHSD management should strengthen its policies and procedures to ensure that regulations set forth by 2 CFR 200.332 are being addressed timely.Management?s Response and Corrective Action Plan:Management concurred with the finding and outlined a plan of corrective action (B-2).
2022-018 - Inadequate Controls over Subrecipient AgreementsAward Years: 2019 - 2022Award Numbers: 2201LATANF, B08TI083018-01, B08TI083450-01, B09SM082603-01, B09SM083804-01, H79SM083477, H79SP081004, H79TI081691, X06SM016019-19, X06SM083694-01Compliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Acadiana Area Human Services District (AAHSD) failed to comply with all regulations set forth by 2 CFR 200.332.AAHSD is allocated federal funds from the Louisiana Department of Health (LDH), Office of Behavioral Health (OBH) as interagency transfers, and AAHSD passes these funds to other entities via contracts to perform consulting, social, and professional services. The federal programs involved had awards totaling $3,895,985 and $6,108,836 allocated to AAHSD for fiscal years 2021 and 2022, respectively.We reviewed all 28 agreements identified by AAHSD as subrecipients and determined that for 18 (64%) of the subawards, AAHSD was unable to provide documentation of whether each subrecipient was required to obtain an audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for all 28 of the subrecipients, AAHSD could not provide evidence that the required risk assessment was performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria:Federal regulations require AAHSD, as the pass-through entity, to comply with 2 CFR 200.332 when subawards are made to subrecipients.Cause:AAHSD failed to develop adequate policies and procedures to ensure compliance with regulations set forth by 2 CFR 200.332 were performed timely.Effect:AAHSD or the subrecipient may not comply with the award and federal regulations.Recommendation:AAHSD management should strengthen its policies and procedures to ensure that regulations set forth by 2 CFR 200.332 are being addressed timely.Management?s Response and Corrective Action Plan:Management concurred with the finding and outlined a plan of corrective action (B-2).
2022-018 - Inadequate Controls over Subrecipient AgreementsAward Years: 2019 - 2022Award Numbers: 2201LATANF, B08TI083018-01, B08TI083450-01, B09SM082603-01, B09SM083804-01, H79SM083477, H79SP081004, H79TI081691, X06SM016019-19, X06SM083694-01Compliance Requirement: Subrecipient MonitoringRepeat Finding: NoSee Schedule of Findings and Questioned Costs for chart/tableCondition:The Acadiana Area Human Services District (AAHSD) failed to comply with all regulations set forth by 2 CFR 200.332.AAHSD is allocated federal funds from the Louisiana Department of Health (LDH), Office of Behavioral Health (OBH) as interagency transfers, and AAHSD passes these funds to other entities via contracts to perform consulting, social, and professional services. The federal programs involved had awards totaling $3,895,985 and $6,108,836 allocated to AAHSD for fiscal years 2021 and 2022, respectively.We reviewed all 28 agreements identified by AAHSD as subrecipients and determined that for 18 (64%) of the subawards, AAHSD was unable to provide documentation of whether each subrecipient was required to obtain an audit or that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for all 28 of the subrecipients, AAHSD could not provide evidence that the required risk assessment was performed to evaluate each subrecipients? risk of noncompliance with federal regulations and the terms of the subaward.Criteria:Federal regulations require AAHSD, as the pass-through entity, to comply with 2 CFR 200.332 when subawards are made to subrecipients.Cause:AAHSD failed to develop adequate policies and procedures to ensure compliance with regulations set forth by 2 CFR 200.332 were performed timely.Effect:AAHSD or the subrecipient may not comply with the award and federal regulations.Recommendation:AAHSD management should strengthen its policies and procedures to ensure that regulations set forth by 2 CFR 200.332 are being addressed timely.Management?s Response and Corrective Action Plan:Management concurred with the finding and outlined a plan of corrective action (B-2).
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
CRF Subrecipient Single Audit Report Reviews Not Occurring(Governor?s Office of Planning and Budget)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.019 Coronavirus Relief FundFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AGOPB did not design or implement controls to ensure its subrecipients? single audit reports were monitored according to federal requirements. It also did not review any subrecipients? single audit reports to assess whether its subrecipients receiving CRF funds spent the funds appropriately. 2 CFR 200.332(d) requires a review of subrecipient single audit reports when they become available. It also requires GOPB to follow up with the subrecipient to ensure timely and appropriate action has taken place for any deficiencies identified.GOPB did not design or implement controls because of its unfamiliarity with federal grant requirements and employee turnover. This could result in GOPB not identifying potential issues at the subrecipient level and take appropriate actions.Recommendation:We recommend GOPB establish policies and procedures to ensure monitoring of single audit reports occur in accordance with 2 CFR 200.332(d).GOPB?s Response:GOPB agrees with this finding. Prior to being awarded any CRF funds, GOPB required all subrecipients to agree to the terms and conditions on which the funds were granted. Part of the agreement stated that these federal funds were subject to the Single Audit Act and 2 CFR 200.332(d) requirements, which requires that subrecipients receiving more than $750,000 in federal funds per year complete and submit their single audit report in compliance with federal regulations. All state government agencies are covered under the statewide single audit completed by the Office of the State Auditor, however cities, counties, towns, water districts and other local entities are not covered by the statewide single audit and need to complete their own, if they meet the spending threshold.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Go Utah Did Not Implement Internal Controls for Subrecipient Monitoring Requirements(Go Utah)Federal Agency: Department of the TreasuryAssistance Listing Number and Title: 21.027 Coronavirus State and Local Fiscal Recovery FundsFederal Award Number: N/AQuestioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AThe Governor's Office of Economic Opportunity (Go Utah) did not establish internal controls to ensure compliance with Coronavirus State and Local Fiscal Recovery Funds (SLFRF) subrecipient monitoring requirements. Go Utah also did not properly communicate key federal grant information or evaluate and monitor its subrecipient for compliance purposes as required by 2 CRF 200.332.The Department of Treasury?s Final Rule requires recipients of funds to ?establish rigorous oversight and internal control processes to monitor compliance with any applicable requirements, including compliance by subrecipients.? 2 CFR 200.303 also requires the establishment of effective internal control for federal programs.Go Utah was unaware that subrecipient monitoring requirements were applicable to its program. Failure to establish internal controls, adequately communicate key federal program information to subrecipients and perform risk evaluation, and monitoring procedures may result in the subrecipient?s noncompliance with federal funds and potential misuse of federal funds.Recommendation:We recommend Go Utah:1. Gain an understanding of subrecipient requirements and establish internal controls to ensure compliance with these requirements; and2. Communicate all required federal award information to sub-recipients.Go Utah?s Response:We agree. While internal controls were insufficient, they were not completely absent. For example: (1) we implemented the American Rescue Plan Act of 2021 Appropriation Tracking and Documentation Form, and (2) all sub-recipients signed contracts that included internal controls such as requirements for status reports, performance measures, and compliance with all applicable federal and state laws, rules, and regulations.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Subrecipients Not Tracked for Monitoring of Single Audit Reports(Department of Workforce Services)Federal Agency: Department of Health and Human ServicesAssistance Listing Number and Title: 93.575 Child Care and Development Block GrantFederal Award Number: 2101UTCCDF, 21UTCSC6Questioned Costs: N/APass-through Entity: N/APrior Year Single Audit Report Finding Number: N/AFour of 26 entities receiving Child Care funds as a subrecipient were not included on DWS?s Single Audit tracking log. This log was reviewed and approved, but did not detect these missing subrecipients. 2 CFR 200.332(f) requires the DWS to ?verify that every subrecipient is audited as required by Subpart F? of Uniform Guidance. These entities were not included in the tracking log because the query used to pull Child Care subrecipient entities had an error in it. Because DWS did not identify the subrecipients for review, the subrecipients may not have been audited as required and follow up on findings related to DWS subawards may not have occurred as required. Potential internal control weaknesses or noncompliance at the subrecipient could occur without being detected by the DWS.Recommendation:We recommend DWS strengthen their internal controls to ensure query criteria to pull subrecipients is complete.DWS?s Response:We agree with the finding.
Reference Number:2022-010Prior Year Finding:NoFederal Agency:U.S. Department of the TreasuryState Agency:Department of Community AffairsFederal Program:COVID-19 - Homeowner Assistance FundAssistance Listing Number:21.026Award Number and Year:HAF0019 (2021)Compliance Requirement:Subrecipient MonitoringType of FindingSignificant Deficiency in Internal Control over Compliance, Other MattersCriteria or specific requirement:Compliance ? Per 2 CFR section 200.332(a), all pass-through entities must 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: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; andxiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414.2 CFR section 200.332 also states that pass-through entities must:(d) 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).(e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include:(1) Reviewing financial and performance reports required by the pass-through entity.(2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means.(3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision.(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 be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).Condition:The Department of Community Affairs (Department) did not comply with subrecipient monitoring requirements for the program.Context:The Department issued one subaward under the program and it was noted that the subaward did not include all required Federal Award information, nor did the Department perform a risk assessment of the subrecipient or perform monitoring activities for the award.Questioned costs:None noted.Cause:The Department?s procedures and controls were not effective to ensure the subaward was issued in compliance with Federal requirements, nor that it performed a risk assessment or timely monitoring of subrecipient.Effect:Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance.Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved.Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis.Recommendation:The Department should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.Views of responsible officials:As recommended, the Department of Community Affairs (DCA) will review current procedures to ensure that all subaward information required by the federal Uniform Guidance is included in all subaward contracts and grant agreements. The DCA has also reviewed its current subrecipient monitoring procedures for standard subawards made by the agency and has determined that no internal control enhancements are required. The HAF award was a unique grant relationship for DCA in that the entire award was passed through to another New Jersey State government agency that is a direct affiliate of the Department. Monitoring procedures were determined based on the close working relationship with our affiliate organization and the fact that less than 1 percent of the grant award was expended through June 30, 2022. Current procedures included a risk assessment of the subrecipient and performance of the single audit desk review of the independent audit report. In addition, the Director of Audit, and the Executive Director of the subgrantee affiliate participate in weekly meetings where updates on the program status can be determined. DCA?s subrecipient monitoring plan also includes the hiring of an Integrity Monitor to oversee and monitor the use of the HAF funds as well as compliance with all HAF program reporting requirements. As program disbursement activity is continuing to increase with the HAF program(s) created more fully up and running, DCA is currently targeting the Integrity Monitor hire to take place sometime within the next three to six months.
Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement –Coronavirus Relief Fund (Repeat Finding - 2021-001) FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.019 FEDERAL PROGRAM NAME: Coronavirus Relief Fund FEDERAL AWARD NUMBER: SLT0259 FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $176,562 Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Oklahoma County has not established the following procedures to ensure compliance with the Subrecipient Monitoring requirements: • Identify the award and applicable requirements to the subrecipients. • Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). • 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)). Further, when performing tests over compliance of the federal grant, it was noted that the County did not perform any subrecipient monitoring procedures. In addition, subaward agreements were not designed to ensure the subrecipients understand and use the funds in accordance with federal regulations, and terms and conditions of the subaward. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with federal laws and regulations and grant agreements. Effect of Condition: This condition resulted in noncompliance with federal laws and regulations and grant agreements. Recommendation: OSAI recommends the County comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Management Response: Chairman of the Board of County Commissioners: Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Criteria: GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.332 states: All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward… (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,… (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. (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 areachieved. ... (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals. (f) 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. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations.
Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Requirement – Emergency Rental Assistance Program (Repeat Finding – 2021-002) FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.023 FEDERAL PROGRAM NAME: Emergency Rental Assistance Program FEDERAL AWARD NUMBER: ERAE0514, ERAE0418 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $13,241,928 Condition: During the process of documenting the County’s internal controls regarding federal disbursements, we noted that Oklahoma County has not established the following procedures to ensure compliance with the Subrecipient Monitoring requirements: • Identify the award and applicable requirements to the subrecipients. • Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). • 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)). Further, when performing tests over compliance of the federal grant, it was noted that the County did not perform any subrecipient monitoring procedures. In addition, subaward agreements were not designed to ensure the subrecipients understand and use the funds in accordance with federal regulations, and terms and conditions of the subaward. Cause of Condition: Policies and procedures have not been designed and implemented to ensure the County complies with federal laws and regulations and grant agreements. Effect of Condition: This condition resulted in noncompliance with federal laws and regulations and grant agreements. Recommendation: OSAI recommends the County comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Management Response: Chairman of the Board of County Commissioners: Oklahoma County will comply with federal laws and regulations and grant agreements by creating award agreements that are designed and implemented to ensure Subrecipient Monitoring is performed. Criteria: GAO Standards – Section 2 – Establishing an Effective Internal Control System – OV2.23 states in part: Objectives of an Entity – Compliance Objectives Management conducts activities in accordance with applicable laws and regulations. As part of specifying compliance objectives, the entity determines which laws and regulations apply to the entity. Management is expected to set objectives that incorporate these requirements. 2 CFR § 200.303(a) Internal Controls reads as follows: The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR § 200.332 states: All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward… (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, . . . (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. (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. … (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals (f) 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. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations.
Finding 2022-004 – Subrecipient Monitoring U.S. Department of Homeland Security Montana Department of Disaster and Emergency Services BRIC: Building Resilient Infrastructure and Communities – ALN 97.047 Subrecipient Monitoring Condition: There is no internal control system to perform subrecipient monitoring. The County has one subrecipient under this award and the total subaward is $832,156. The County did not comply with the subrecipient monitor requirements including: identify the award and applicable requirements to the subrecipient, evaluate the subrecipient’s risk of noncompliance for purpose of determining the appropriate subrecipient monitoring, and monitor the subrecipient. Criteria: In accordance with 2 CFR 200.332,a pass-through entity (PTE) must: 1) clearly identify to the subrecipient the award and applicable requirements, 2) evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward, and 3) 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. In addition to procedures identified as necessary based upon the evaluation of the subrecipient risk or subrecipient monitoring, activities must include: a) reviewing financial and programmatic reports required by the PTE, b) following-up and ensuring the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal awards provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means and c) issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE. Cause: The County does not have formal policies in place for subrecipient monitoring. Effect: A failure to perform subrecipient monitoring could result in noncompliance with federal statutes, regulations, and the terms and conditions of the subaward, as well as adjustments to the County’s own records. Questioned Costs: Unknown Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: The County should adopt formal policies and procedures for subrecipient monitoring in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. See separate corrective action plan.
FINDING NO: 2022-002 - Subrecipient Monitoring (Repeated from Prior Year Findings 21-003, 20-004, 19-005, 18-004, and 17-003) Federal Program: McKinney Education for Homeless Children Project No: 21-4920-00 and 22-4920-00 Federal Assistance Listing No: 84.196A Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education AND Federal Program: COVID-19 ARP - McKinney Education for Homeless Children Project No: 22-4998-HM Federal Assistance Listing No: 84.425W Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure any subrecipient monitoring using federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332. B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Audit procedures revealed that ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards as follows: McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. COVID-19 ARP - McKinney Education for Homeless Children – for two (2) of two (2) subrecipients tested, ROE #47: • Did not identify the subaward and applicable requirements in the agreements. • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. Questioned Costs: None Context: The Regional Office of Education #47 expended a total of $990,919 of federal awards in fiscal year 2022, of which $274,520 in McKinney Education for Homeless Children and $61,075 in COVID-19 ARP - McKinney Education for Homeless Children were passed-through to subrecipients. Effect: The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs. Cause: Regional Office management had not been asked to distribute Federal ARP funds before. All the funds were distributed to public school districts that are subject to state audits every year themselves and we mistakenly did not follow up to get the results of their audits. Recommendation: We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes: a. Identifying the subaward and applicable requirements in the agreements; b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward; c. Conducting subrecipient monitoring procedures; and d. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. Management’s Response: Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
FINDING NO: 2022-002 - Subrecipient Monitoring (Repeated from Prior Year Findings 21-003, 20-004, 19-005, 18-004, and 17-003) Federal Program: McKinney Education for Homeless Children Project No: 21-4920-00 and 22-4920-00 Federal Assistance Listing No: 84.196A Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education AND Federal Program: COVID-19 ARP - McKinney Education for Homeless Children Project No: 22-4998-HM Federal Assistance Listing No: 84.425W Passed Through: Illinois State Board of Education Federal Agency: U.S. Department of Education Criteria/Specific Requirement: A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure any subrecipient monitoring using federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332. B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition: Audit procedures revealed that ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards as follows: McKinney Education for Homeless Children – for three (3) of three (3) subrecipients tested, ROE #47: • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. COVID-19 ARP - McKinney Education for Homeless Children – for two (2) of two (2) subrecipients tested, ROE #47: • Did not identify the subaward and applicable requirements in the agreements. • Did not evaluate the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward. • Did not conduct subrecipient monitoring procedures. • Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit requirements criteria for a single audit. Questioned Costs: None Context: The Regional Office of Education #47 expended a total of $990,919 of federal awards in fiscal year 2022, of which $274,520 in McKinney Education for Homeless Children and $61,075 in COVID-19 ARP - McKinney Education for Homeless Children were passed-through to subrecipients. Effect: The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs. Cause: Regional Office management had not been asked to distribute Federal ARP funds before. All the funds were distributed to public school districts that are subject to state audits every year themselves and we mistakenly did not follow up to get the results of their audits. Recommendation: We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes: a. Identifying the subaward and applicable requirements in the agreements; b. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward; c. Conducting subrecipient monitoring procedures; and d. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit. Management’s Response: Effective April 2024, the Regional Office will formally identify the subaward and the applicable requirements in our agreements. We will conduct subrecipient monitoring procedures. We will determine if the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements for a single audit.
Finding 2022-006 Internal Control and Compliance over Subrecipient Monitoring Information on the Federal Program: Assistance Listing Number(s): 17.258, 17.259, 17.278 Federal Program Name: Workforce Innovation and Opportunity Act (WIOA) Federal Agency: U.S. Department of Labor Pass-Through Entity: California Employment Development Department Federal Award Number and Award Year: AA311008 - FY21-22 Criteria: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Standards for Financial and Program Management. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2: Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D - Post Federal Award Requirements, Subrecipient Monitoring and Management, §200.331 Requirements for pass-through entities (2 CFR 200.331): All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) 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 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; Title 2: Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D - Post Federal Award Requirements, Subrecipient Monitoring and Management, §200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (a) 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 of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During our testing of the Imperial County Workforce Development Office’s (ICWDO) provisions for subrecipient monitoring under the WIOA Cluster, we noted the following instances: For one (1) of the one (1) subrecipient selected for testing, there was no review or approval over the monitoring procedures performed by ICWDO monitoring staff. The entire population of one (1) subrecipient. • The following information was not provided at the time of the subaward for one (1) of the one (1) subaward selected for testing: o Federal award identification number o Federal award date of award to recipient by the Federal agency o Name of federal awarding agency o Federal Financial Assistance Listing/CFDA Number o Identification of whether the award is research and development • The County did not document their evaluation of each subrecipient’s risk of noncompliance Cause: The County’s ICWDO department does not have a formal procedure in place for the department’s review and approval over the monitoring procedures performed by the department over its subrecipients. The ICWDO department did not ensure that the required award information and applicable requirements were communicated to the subrecipients and did not maintain documentation of their evaluation of each subrecipient’s risk of noncompliance. Effect: The County’s ICWDO department did not review and approve monitoring procedures performed over its subrecipients. Additionally, the ICWDO department did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 (a) and 200.332(b). Identification as a Repeat Finding, If Applicable: Yes. See Finding 2021-008. Questioned Costs: No questioned costs were identified. Recommendation: Social Services should continue to monitor compliance with its policies to ensure case workers follow the established guidelines for redetermination of the recipients of need and amount of assistance and retain acceptable documentation to support the determinations. View of Responsible Officials and Planned Corrective Action: See separate Corrective Action Plan.
Finding 2022-006 Internal Control and Compliance over Subrecipient Monitoring Information on the Federal Program: Assistance Listing Number(s): 17.258, 17.259, 17.278 Federal Program Name: Workforce Innovation and Opportunity Act (WIOA) Federal Agency: U.S. Department of Labor Pass-Through Entity: California Employment Development Department Federal Award Number and Award Year: AA311008 - FY21-22 Criteria: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Standards for Financial and Program Management. §200.303 Internal controls (2 CFR 200.303): The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Title 2: Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D - Post Federal Award Requirements, Subrecipient Monitoring and Management, §200.331 Requirements for pass-through entities (2 CFR 200.331): All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) 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 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; Title 2: Grants and Agreements, Subtitle A - Office of Management and Budget Guidance for Grants and Agreements, Chapter II - Office of Management and Budget Guidance, Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Subpart D - Post Federal Award Requirements, Subrecipient Monitoring and Management, §200.332 Requirements for pass-through entities (2 CFR 200.332): All pass-through entities must: (a) 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 of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During our testing of the Imperial County Workforce Development Office’s (ICWDO) provisions for subrecipient monitoring under the WIOA Cluster, we noted the following instances: For one (1) of the one (1) subrecipient selected for testing, there was no review or approval over the monitoring procedures performed by ICWDO monitoring staff. The entire population of one (1) subrecipient. • The following information was not provided at the time of the subaward for one (1) of the one (1) subaward selected for testing: o Federal award identification number o Federal award date of award to recipient by the Federal agency o Name of federal awarding agency o Federal Financial Assistance Listing/CFDA Number o Identification of whether the award is research and development • The County did not document their evaluation of each subrecipient’s risk of noncompliance Cause: The County’s ICWDO department does not have a formal procedure in place for the department’s review and approval over the monitoring procedures performed by the department over its subrecipients. The ICWDO department did not ensure that the required award information and applicable requirements were communicated to the subrecipients and did not maintain documentation of their evaluation of each subrecipient’s risk of noncompliance. Effect: The County’s ICWDO department did not review and approve monitoring procedures performed over its subrecipients. Additionally, the ICWDO department did not maintain policies and procedures to align with the Subrecipient Monitoring requirements in 2 CFR 200.332 (a) and 200.332(b). Identification as a Repeat Finding, If Applicable: Yes. See Finding 2021-008. Questioned Costs: No questioned costs were identified. Recommendation: Social Services should continue to monitor compliance with its policies to ensure case workers follow the established guidelines for redetermination of the recipients of need and amount of assistance and retain acceptable documentation to support the determinations. View of Responsible Officials and Planned Corrective Action: See separate Corrective Action Plan.