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.
Criteria: Internal 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). Compliance: Monitoring the activities of the subrecipients 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)). Condition: the County did not provide documentation to support subrecipient monitoring for all subawards issued during fiscal year 2022. Cause: the County’s Finance Office was unaware of subrecipient monitoring requirements for all federally funded subawards of $25,000 or more. Questioned Costs: None Effect: Federal funds may be used for purposes that are not in accordance with the terms of the grant agreement. Recommendation: We recommend the County review and enhance internal controls and procedures to ensure that all subrecipients are monitored and reviewed. Identification of Repeat Finding: This is a first year finding. Views of Responsible Officials: management agrees with the finding.
Finding 2022-007 — Lack of Internal Controls and Noncompliance with Subrecipient Monitoring – Emergency Rental Assistance Program (Repeat Finding 2021-013) FEDERAL AGENCY: U.S. Department of the Treasury ASSISTANCE LISTING: 21.023 FEDERAL PROGRAM NAME: Emergency Rental Assistance Program FEDERAL AWARD NUMBER: ERA0174, ERAE0225 FEDERAL AWARD YEAR: 2022 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $6,397,374 Condition: During the process of documenting the County’s internal controls regarding federal disbursements for the Emergency Rental Assistance Program (ERA), we noted that Cleveland County has not established the following procedures to ensure compliance with the Subrecipient Monitoring requirements: • Evaluate subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward. • 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. Further, while documenting controls over the subrecipient program and administrative expenditures for the ERA1, we noted the following: • The County was unable to provide supporting documents for the administrative costs of the consultant for this grant totaling $64,800. • The County was unable to provide supporting documentation of the subrecipient’s administrative expenditures totaling $453,067. 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; and adequate subrecipient monitoring policies and procedures had not been established by the County prior to entering into agreements with subrecipients. Effect of Condition: This condition resulted in noncompliance with grant requirements. Also, the subrecipient may not be in compliance with the award terms and there is an increased risk of mismanagement and fraud by the subgrantees. Recommendation: OSAI recommends the County design and implement internal controls to ensure that it administers current and future ERA grants in accordance with applicable federal laws and grant requirements, including ensuring that grant subrecipients are properly informed of federal requirements related to allowable costs and that subrecipient monitoring procedures are designed and implemented. Subrecipients should be reimbursed for administrative costs based on supporting documentation for actual costs incurred rather than making advance payments for a set percentage of program funds advanced. Management Response: Chairman of the Board of County Commissioners: Cleveland County takes the auditor's findings seriously and has already implemented several improvements in documentation, monitoring, and reporting practices. Cleveland County is working toward improvements for fiscal year 2025 and has reconciled billing to align with the contract scope of work. However, we recognize the need for documented internal controls and are committed to addressing all recommendations to ensure compliance and transparency in future programs. The County appreciates the constructive feedback and will continue to refine its processes to better serve its citizens. 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 § 200.332 states in part: (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In addition, identify procedures necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: 1. Reviewing financial and programmatic (performance and special reports) required by the Pass-Through Entity (PTE). The Consolidated Appropriations Act§ Section 501 (c)(5) Use of Funds - Administrative Costs states in part: (A) IN GENERAL. —Not more than 10 percent of the amount paid to an eligible grantee under this section may be used for administrative costs attributable to providing financial assistance and housing stability services under paragraphs (2) and (3), respectively, including for data collection and reporting requirements related to such funds. (B) NO OTHER ADMINISTRATIVE COSTS. —Amounts paid under this section shall not be used for any administrative costs other than to the extent allowed under subparagraph (A). In addition, the U.S. Department of Treasury Emergency Rental Assistance (ERA) FAQ #29 What are the applicable limitations on administrative expenses, states in part: Under ERAl, not more than 10 percent of the amount paid to a grantee may be used for administrative costs attributable to providing financial assistance and housing stability services to eligible households. Under ERA2, not more than 15 percent of the amount paid to a grantee may be used for administrative costs attributable to providing financial assistance, housing stability services, and other affordable rental housing and eviction prevention activities. 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.
Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Recommendation We recommend that the Organization incorporate the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards. Views of Responsible Officials and Planned Corrective Action The Organization concurs with the recommendation. As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance, perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions. Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.
Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Recommendation We recommend that the Organization incorporate the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards. Views of Responsible Officials and Planned Corrective Action The Organization concurs with the recommendation. As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance, perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions. Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.
Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Recommendation We recommend that the Organization incorporate the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards. Views of Responsible Officials and Planned Corrective Action The Organization concurs with the recommendation. As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance, perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions. Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.
Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Recommendation We recommend that the Organization incorporate the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards. Views of Responsible Officials and Planned Corrective Action The Organization concurs with the recommendation. As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance, perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions. Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.
Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Recommendation We recommend that the Organization incorporate the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards. Views of Responsible Officials and Planned Corrective Action The Organization concurs with the recommendation. As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance, perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions. Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.
Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Recommendation We recommend that the Organization incorporate the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards. Views of Responsible Officials and Planned Corrective Action The Organization concurs with the recommendation. As part of our current policies and procedures review and revision process, we plan to incorporate the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance to emphasize accountability and compliance in managing federal funds and subrecipients. Specifically and prospectively, effective November 1, 2024, the Organization’s practices will include: 1. Using a checklist for the determination of subrecipient or contractor classification as guidance, perform a comprehensive risk assessment before entering into any subrecipient agreement. 2. Provide identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards. 3. Require subrecipients to submit programmatic and financial reports as specified in the subrecipient agreement. 4. As part of the subrecipient process, ensure subrecipients that expend $750,000 or more in federal funds during a fiscal year undergo a single audit in accordance with 2 CFR Part 200, Subpart F. Review their audit reports and address any findings related to their federal awards, taking appropriate corrective actions. Retroactively, for the audit periods July 1, 2022 – June 30, 2023 and July 1, 2023 – June 30, 2024, the Organization will perform a risk assessment of the existing subrecipient portfolio during this period to identify high-priority risks. The objective of this risk assessment review is to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, and quality assurance goals, ensuring that all products, services, and processes align with established standards and fulfill processes. The above reflects the current planned practices of the Organization and the overall financial policies and procedures are in the process of being updated to align to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance. The Organization has prioritized the completion and distribution of the updated financial policies and procedures by December 31, 2024.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9-7-29 (D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state. Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings. 2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities. 3. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. 4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. 5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021 does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022. 6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services. The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9-7-29 (D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state. Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings. 2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities. 3. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. 4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. 5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021 does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022. 6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services. The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9-7-29 (D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state. Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings. 2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities. 3. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. 4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. 5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021 does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022. 6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services. The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9-7-29 (D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state. Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings. 2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities. 3. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. 4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. 5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021 does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022. 6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services. The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9-7-29 (D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state. Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings. 2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities. 3. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. 4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. 5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021 does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022. 6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services. The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9-7-29 (D)(2)(c) requires WIOA local area fiscal agents to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code § 5101:9-7-29(D)(1)(b)(i) further requires the fiscal agent, when reviewing the quarterly financial data, to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. Ohio Admin Code § 5101:9-7-04(E) states in part that as expenditures are incurred, they become accrued expenses and shall be reported as accruals. Ohio Admin Code § 5101:9-7-04(F) provides that the WIOA local area shall maintain documentation in accordance with the records retention requirements in rule 5101:9-9-21 of the Administrative Code. This documentation may be subject to inspection, monitoring, and audit by ODJFS and the Ohio auditor of state. Due to the lack of effect control procedures over reporting, the following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the third quarter of calendar year 2021 was not filed until December 1, 2021, the fourth quarter of calendar year 2021 was not filed until February 14, 2022, the second quarter of calendar year 2022 was not filed until August 12, 2022, the third quarter of calendar year 2022 was not filed until November 16, 2022, the fourth quarter of calendar year 2022 was not filed until February 13, 2023. These were considered late filings. 2. The fiscal agent did not maintain quarterly certification on file for the first quarter of calendar year 2022. Copies had to be obtained from CFIS and those copies were not the originals signed by approving authorities. 3. For all submissions, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. 4. For all submissions, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. 5. The ending balance reported on the quarterly financial certification for the second quarter of calendar year 2022 did not agree to the beginning balance reported for the third quarter of calendar year 2022, the ending balance reported on the quarterly financial certification for the second quarter of calendar year 2021 does not agree to the beginning balance of the third quarter of calendar year 2021, the ending balance reported on the quarterly financial certification for the 4th quarter of calendar year 2021 did not agree to the beginning balance of the first quarter of calendar year 2022. 6. For the fourth quarter of 2021, the month to month beginning and ending balances do not agree. This could lead to questions regarding accuracy of the amounts reported to the Ohio Department of Job and Family Services. The Consortium should develop and implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
Department: United States Department of Housing and Urban Development Program Name: Emergency Solutions Grant Program Federal Assistance Listing Number: 14.231 Significant deficiency – Subrecipient monitoring Criteria: As described in Part 2 CFR Part 200, Subpart D, section 200.332 a pass-through entity must clearly identify to the subrecipient as a subaward and include certain key information at the time of the subaward. One such key item is the dollar amount made available under each federal award and the Assistance Listing number. Condition: While performing our audit of the Organization’s subrecipient monitoring, we noted the Organization did not include Assistance Listing number to the subrecipient at the time of the subaward. Cause: The Organization has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect: Noncompliance may impact future funding from federal and state awarding agencies. Questioned Costs: None. Repeat Finding: No Recommendation: We recommend the Organization develop agreements with subrecipients to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332. View of Responsible Official: We agree with this finding and will include the relevant information in our subawards in the future.
Department: United States Department of Housing and Urban Development Program Name: Emergency Solutions Grant Program Federal Assistance Listing Number: 14.231 Significant deficiency – Subrecipient monitoring Criteria: As described in Part 2 CFR Part 200, Subpart D, section 200.332 a pass-through entity must clearly identify to the subrecipient as a subaward and include certain key information at the time of the subaward. One such key item is the dollar amount made available under each federal award and the Assistance Listing number. Condition: While performing our audit of the Organization’s subrecipient monitoring, we noted the Organization did not include Assistance Listing number to the subrecipient at the time of the subaward. Cause: The Organization has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect: Noncompliance may impact future funding from federal and state awarding agencies. Questioned Costs: None. Repeat Finding: No Recommendation: We recommend the Organization develop agreements with subrecipients to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332. View of Responsible Official: We agree with this finding and will include the relevant information in our subawards in the future.
Department: United States Department of Housing and Urban Development Program Name: Emergency Solutions Grant Program Federal Assistance Listing Number: 14.231 Significant deficiency – Subrecipient monitoring Criteria: As described in Part 2 CFR Part 200, Subpart D, section 200.332 a pass-through entity must clearly identify to the subrecipient as a subaward and include certain key information at the time of the subaward. One such key item is the dollar amount made available under each federal award and the Assistance Listing number. Condition: While performing our audit of the Organization’s subrecipient monitoring, we noted the Organization did not include Assistance Listing number to the subrecipient at the time of the subaward. Cause: The Organization has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect: Noncompliance may impact future funding from federal and state awarding agencies. Questioned Costs: None. Repeat Finding: No Recommendation: We recommend the Organization develop agreements with subrecipients to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332. View of Responsible Official: We agree with this finding and will include the relevant information in our subawards in the future.
Department: United States Department of Housing and Urban Development Program Name: Emergency Solutions Grant Program Federal Assistance Listing Number: 14.231 Significant deficiency – Subrecipient monitoring Criteria: As described in Part 2 CFR Part 200, Subpart D, section 200.332 a pass-through entity must clearly identify to the subrecipient as a subaward and include certain key information at the time of the subaward. One such key item is the dollar amount made available under each federal award and the Assistance Listing number. Condition: While performing our audit of the Organization’s subrecipient monitoring, we noted the Organization did not include Assistance Listing number to the subrecipient at the time of the subaward. Cause: The Organization has not implemented sufficient internal control policies to adhere to the requirements of Uniform Guidance. Effect: Noncompliance may impact future funding from federal and state awarding agencies. Questioned Costs: None. Repeat Finding: No Recommendation: We recommend the Organization develop agreements with subrecipients to properly reflect each of the required elements included in Part 2 CFR Part 200, Subpart D, section 200.332. View of Responsible Official: We agree with this finding and will include the relevant information in our subawards in the future.
Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, it was noted the County had one (1) subrecipient and the County did not have a subrecipient monitoring policy, and the County did not obtain subrecipient agreements comprising the following information: • Subrecipient name. • Subrecipient Authorized Representative and program contact information. • Subrecipient Employee Identification Number (EIN) and DUNS number. • Federal Award Identification Number (FAIN). • Name of Federal Awarding Agency. • Contact information for the official at the Federal Awarding Agency. • Catalog of Assistance Listing (AL) number and name. • Federal award date. • Total amount of the federal award and indirect cost rate. • Federal award project description. • Start and end date of the agreement. • Amount of federal funds budgeted for the agreement and indirect cost rate allowed. • A statement that all activities must be in accordance with federal statutes, regulations, and terms and conditions of the federal award. The subrecipient should receive a copy of the award documents. • A detailed description of any additional requirements you want the subrecipient to be responsible for such as performance and/or financial reports, attending meetings and/or trainings, etc. • A statement about the monitoring activities, such as where/when they will take place; also include a statement indicating the subrecipient will collaborate on monitoring activities including providing requested financial documents. • A statement indicating if any of the items in the agreement change during the period of performance, the agreement will be amended. Provide close out terms and conditions. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with compliance requirements. Effect of Condition: This condition resulted in noncompliance with federal grant guidelines. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration. Criteria: 2 CFR 200 §200.332 Requirement for Pass-Through Entities states in part: 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. (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. (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part. (6) Appropriate terms and conditions concerning closeout of the subaward.
Criteria or specific requirement: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. ? Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Condition: We noted the Organization is not in compliance with requirements related to the subrecipient monitoring of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization lacked a process to review the audits of subrecipients that would allow the Organization to identify any potential deficiencies that would require follow-up. ? The Organization lacked a process to complete a risk assessment that would allow the Organization 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. Cause: The Organization does not have internal controls in place to ensure compliance with Federal regulations or the terms and conditions of the Federal award. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients. Repeat Finding: Yes ? 2021-004 Recommendation: We recommend that the Organization create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have since followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors and one as a subrecipient which is described below: ? Union County General Hospital (UCGH): Both ROAMS and UCGH see this relationship as a contractor. The stipend pays for a Tele-OB room in their facility and the budget even lists rent as part of the reason for the stipend. The stipend per the MoU also supports their participation in the monthly Governing Council meetings, data collection, IT support for the program implementation and decision making. ? Questa Health Center/Presbyterian Medical Services (Questa): Both ROAMS and Questa see this relationship as a contractor. The stipend pays for an OB room in their facility and is even listed as rent in the stipend budget. The stipend per the MoU also supports their participation in the monthly Governing Council and decision making. ? UNM Envision (UNM): UNM declared a portion of their stipend over the three-year period they received as subrecipient. They declared $39,635 as subrecipient and they received a total of $68,000 from ROAMS. ROAMS always saw the relationship as a contractor and not a subrecipient and we do not understand why they have declared a portion of their stipend as subrecipient. UNM was not an essential grant partner, joined in year two to assist with data review, participated in the Governing Council, and ROAMS has a data evaluation agreement with UNM that we understood as a contract. This different understanding of the relationships highlights the audit finding that the type of relationship should be agreed upon upfront. ? Miners Colfax Medical Center (MCMC): sees themselves as a subrecipient and we agree. They are a state hospital and the other Labor and Delivery hospital in the ROAMS grant, and like Holy Cross Medical Center have a very high data reporting burden and serve as the home for the patients. The Memorandum of Agreement signed by all Network partners outlines their obligations in section IV Provision of Services and VI Records and Information (a. b. and c.). As we have investigated the monitoring of subrecipients verses a contractor, we have found that the same follow up is necessary, as long as the subrecipient receives less than $750,000 in federal funds in a year, which is the case for MCMC. Our procedures for paying the stipend for both the contractors and one subrecipient (MCMC), have been attendance at the monthly Governing Council meetings, and deliverables from data collection, to IT support and meetings, workflow meetings, and clinical meetings. Reminders of deliverables that are pending are in the monthly Governing Council notes as is the attendance. ROAMS and the network partners were very clear in written documents and practice that the quarterly stipend payment was linked to participation and deliverables. We can provide you with monthly Governing Council notes to show this. A draft policy is in the works that will have the network partners formally declare their relationship as contractor or subrecipient and outline the monitoring of subrecipients. From our research we do not see the subrecipient monitoring being significantly different from a contractor unless the $750,000 threshold is met. The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors. The ROAMS Director will request from the entities the audits for the CFO review to review for deficiencies on an annual basis.
Criteria or specific requirement: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. ? Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Condition: We noted the Organization is not in compliance with requirements related to the subrecipient monitoring of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization lacked a process to review the audits of subrecipients that would allow the Organization to identify any potential deficiencies that would require follow-up. ? The Organization lacked a process to complete a risk assessment that would allow the Organization 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. Cause: The Organization does not have internal controls in place to ensure compliance with Federal regulations or the terms and conditions of the Federal award. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients. Repeat Finding: Yes ? 2021-004 Recommendation: We recommend that the Organization create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have since followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors and one as a subrecipient which is described below: ? Union County General Hospital (UCGH): Both ROAMS and UCGH see this relationship as a contractor. The stipend pays for a Tele-OB room in their facility and the budget even lists rent as part of the reason for the stipend. The stipend per the MoU also supports their participation in the monthly Governing Council meetings, data collection, IT support for the program implementation and decision making. ? Questa Health Center/Presbyterian Medical Services (Questa): Both ROAMS and Questa see this relationship as a contractor. The stipend pays for an OB room in their facility and is even listed as rent in the stipend budget. The stipend per the MoU also supports their participation in the monthly Governing Council and decision making. ? UNM Envision (UNM): UNM declared a portion of their stipend over the three-year period they received as subrecipient. They declared $39,635 as subrecipient and they received a total of $68,000 from ROAMS. ROAMS always saw the relationship as a contractor and not a subrecipient and we do not understand why they have declared a portion of their stipend as subrecipient. UNM was not an essential grant partner, joined in year two to assist with data review, participated in the Governing Council, and ROAMS has a data evaluation agreement with UNM that we understood as a contract. This different understanding of the relationships highlights the audit finding that the type of relationship should be agreed upon upfront. ? Miners Colfax Medical Center (MCMC): sees themselves as a subrecipient and we agree. They are a state hospital and the other Labor and Delivery hospital in the ROAMS grant, and like Holy Cross Medical Center have a very high data reporting burden and serve as the home for the patients. The Memorandum of Agreement signed by all Network partners outlines their obligations in section IV Provision of Services and VI Records and Information (a. b. and c.). As we have investigated the monitoring of subrecipients verses a contractor, we have found that the same follow up is necessary, as long as the subrecipient receives less than $750,000 in federal funds in a year, which is the case for MCMC. Our procedures for paying the stipend for both the contractors and one subrecipient (MCMC), have been attendance at the monthly Governing Council meetings, and deliverables from data collection, to IT support and meetings, workflow meetings, and clinical meetings. Reminders of deliverables that are pending are in the monthly Governing Council notes as is the attendance. ROAMS and the network partners were very clear in written documents and practice that the quarterly stipend payment was linked to participation and deliverables. We can provide you with monthly Governing Council notes to show this. A draft policy is in the works that will have the network partners formally declare their relationship as contractor or subrecipient and outline the monitoring of subrecipients. From our research we do not see the subrecipient monitoring being significantly different from a contractor unless the $750,000 threshold is met. The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors. The ROAMS Director will request from the entities the audits for the CFO review to review for deficiencies on an annual basis.
Federal Agency: United States Department of Agriculture Federal Programs: Child and Adult Care Food Program (10.558) Federal Award Numbers: 202120N105044, 202121N115044, 202222N115044, 202221N115044, 202121N202044, 202120N202044, 202121N109944, 202120N109944, 202121N119944, 202121H170644, 202222N202044, 202221N202044, 202222N119944, 202221N119944 Federal Award Years: 2021 and 2022 State Agency: Department of Health Reference: 2022-003 Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.332(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that he 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 2 CFR 200.521. Additionally, 2 CFR 200.303(a) states the nonfederal entity must Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition For 3 of 40 subrecipients selected, the Department did not review the cases by the scheduled due date for the single audit reports as required in accordance with 2 CFR 200.332(d). The Department of Health (the Department) did not have effective internal controls in place to ensure that all required single audits of the program?s subrecipients were reviewed, followed-up, or appropriate action was taken and as necessary issued a management decision pertaining to the audit finding in accordance with 2 CFR 200, as applicable. The Department maintains an internal clearinghouse tracker (the tracker) to track the subrecipients single audit status. The tracker tracks subrecipients that are exempt from single audit requirements as well as the status and follow-up required for the subrecipients with single audits. Cause The condition is due to DOH Audit Clearinghouse personnel not operating as intended, due to COVID-19 personnel reassignments, to ensure the timely review of all single audit reports for all subrecipients receiving federal funding from the Department. Possible Asserted Effect Failure to properly obtain and review subrecipient single audit reports may result in the use of federal funding not being in compliance with federal statues, regulations, and the terms and conditions of subawards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding for the Department was included in the 2019 Single Audit Report as finding number 2019 032 at pages 90?92. Recommendation We recommend the Department to continue working on the implementation of its replacement computerized system to (1) identify all subrecipients required to have a single audit, (2) ensure that sanctions are imposed in a timely manner for subrecipients that do not submit timely single audit reports, and (3) issue management decisions within six months for all single audit reports that contain findings relevant to the Department?s programs. In the interim, we recommend that manual internal control procedures be implemented by the Department to ensure that all subrecipients that require a single audit to be completed submit the report on a timely basis and, if applicable, respond to management decision letters be issued by the Department. Views of Responsible Officials Recommendation accepted. Reference the corrective action plan for further details.
Federal Agency: United States Department of Agriculture Federal Programs: Child and Adult Care Food Program (10.558) Federal Award Numbers: 202120N105044, 202121N115044, 202222N115044, 202221N115044, 202121N202044, 202120N202044, 202121N109944, 202120N109944, 202121N119944, 202121H170644, 202222N202044, 202221N202044, 202222N119944, 202221N119944 Federal Award Years: 2021 and 2022 State Agency: Department of Health Reference: 2022-003 Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.332(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that he 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 2 CFR 200.521. Additionally, 2 CFR 200.303(a) states the nonfederal entity must Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition For 3 of 40 subrecipients selected, the Department did not review the cases by the scheduled due date for the single audit reports as required in accordance with 2 CFR 200.332(d). The Department of Health (the Department) did not have effective internal controls in place to ensure that all required single audits of the program?s subrecipients were reviewed, followed-up, or appropriate action was taken and as necessary issued a management decision pertaining to the audit finding in accordance with 2 CFR 200, as applicable. The Department maintains an internal clearinghouse tracker (the tracker) to track the subrecipients single audit status. The tracker tracks subrecipients that are exempt from single audit requirements as well as the status and follow-up required for the subrecipients with single audits. Cause The condition is due to DOH Audit Clearinghouse personnel not operating as intended, due to COVID-19 personnel reassignments, to ensure the timely review of all single audit reports for all subrecipients receiving federal funding from the Department. Possible Asserted Effect Failure to properly obtain and review subrecipient single audit reports may result in the use of federal funding not being in compliance with federal statues, regulations, and the terms and conditions of subawards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding for the Department was included in the 2019 Single Audit Report as finding number 2019 032 at pages 90?92. Recommendation We recommend the Department to continue working on the implementation of its replacement computerized system to (1) identify all subrecipients required to have a single audit, (2) ensure that sanctions are imposed in a timely manner for subrecipients that do not submit timely single audit reports, and (3) issue management decisions within six months for all single audit reports that contain findings relevant to the Department?s programs. In the interim, we recommend that manual internal control procedures be implemented by the Department to ensure that all subrecipients that require a single audit to be completed submit the report on a timely basis and, if applicable, respond to management decision letters be issued by the Department. Views of Responsible Officials Recommendation accepted. Reference the corrective action plan for further details.
Federal Agency: United States Department of Agriculture Federal Programs: Child and Adult Care Food Program (10.558) Federal Award Numbers: 202120N105044, 202121N115044, 202222N115044, 202221N115044, 202121N202044, 202120N202044, 202121N109944, 202120N109944, 202121N119944, 202121H170644, 202222N202044, 202221N202044, 202222N119944, 202221N119944 Federal Award Years: 2021 and 2022 State Agency: Department of Health Reference: 2022-003 Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.332(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that he 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 2 CFR 200.521. Additionally, 2 CFR 200.303(a) states the nonfederal entity must Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition For 3 of 40 subrecipients selected, the Department did not review the cases by the scheduled due date for the single audit reports as required in accordance with 2 CFR 200.332(d). The Department of Health (the Department) did not have effective internal controls in place to ensure that all required single audits of the program?s subrecipients were reviewed, followed-up, or appropriate action was taken and as necessary issued a management decision pertaining to the audit finding in accordance with 2 CFR 200, as applicable. The Department maintains an internal clearinghouse tracker (the tracker) to track the subrecipients single audit status. The tracker tracks subrecipients that are exempt from single audit requirements as well as the status and follow-up required for the subrecipients with single audits. Cause The condition is due to DOH Audit Clearinghouse personnel not operating as intended, due to COVID-19 personnel reassignments, to ensure the timely review of all single audit reports for all subrecipients receiving federal funding from the Department. Possible Asserted Effect Failure to properly obtain and review subrecipient single audit reports may result in the use of federal funding not being in compliance with federal statues, regulations, and the terms and conditions of subawards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding for the Department was included in the 2019 Single Audit Report as finding number 2019 032 at pages 90?92. Recommendation We recommend the Department to continue working on the implementation of its replacement computerized system to (1) identify all subrecipients required to have a single audit, (2) ensure that sanctions are imposed in a timely manner for subrecipients that do not submit timely single audit reports, and (3) issue management decisions within six months for all single audit reports that contain findings relevant to the Department?s programs. In the interim, we recommend that manual internal control procedures be implemented by the Department to ensure that all subrecipients that require a single audit to be completed submit the report on a timely basis and, if applicable, respond to management decision letters be issued by the Department. Views of Responsible Officials Recommendation accepted. Reference the corrective action plan for further details.
Federal Agency: United States Department of Agriculture Federal Programs: Child and Adult Care Food Program (10.558) Federal Award Numbers: 202120N105044, 202121N115044, 202222N115044, 202221N115044, 202121N202044, 202120N202044, 202121N109944, 202120N109944, 202121N119944, 202121H170644, 202222N202044, 202221N202044, 202222N119944, 202221N119944 Federal Award Years: 2021 and 2022 State Agency: Department of Health Reference: 2022-003 Criteria Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200), Uniform Administrative Requirements, Cost Principles, and Audit Requirements, section 200.332(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that he 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 2 CFR 200.521. Additionally, 2 CFR 200.303(a) states the nonfederal entity must Establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition For 3 of 40 subrecipients selected, the Department did not review the cases by the scheduled due date for the single audit reports as required in accordance with 2 CFR 200.332(d). The Department of Health (the Department) did not have effective internal controls in place to ensure that all required single audits of the program?s subrecipients were reviewed, followed-up, or appropriate action was taken and as necessary issued a management decision pertaining to the audit finding in accordance with 2 CFR 200, as applicable. The Department maintains an internal clearinghouse tracker (the tracker) to track the subrecipients single audit status. The tracker tracks subrecipients that are exempt from single audit requirements as well as the status and follow-up required for the subrecipients with single audits. Cause The condition is due to DOH Audit Clearinghouse personnel not operating as intended, due to COVID-19 personnel reassignments, to ensure the timely review of all single audit reports for all subrecipients receiving federal funding from the Department. Possible Asserted Effect Failure to properly obtain and review subrecipient single audit reports may result in the use of federal funding not being in compliance with federal statues, regulations, and the terms and conditions of subawards. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding A similar finding for the Department was included in the 2019 Single Audit Report as finding number 2019 032 at pages 90?92. Recommendation We recommend the Department to continue working on the implementation of its replacement computerized system to (1) identify all subrecipients required to have a single audit, (2) ensure that sanctions are imposed in a timely manner for subrecipients that do not submit timely single audit reports, and (3) issue management decisions within six months for all single audit reports that contain findings relevant to the Department?s programs. In the interim, we recommend that manual internal control procedures be implemented by the Department to ensure that all subrecipients that require a single audit to be completed submit the report on a timely basis and, if applicable, respond to management decision letters be issued by the Department. Views of Responsible Officials Recommendation accepted. Reference the corrective action plan for further details.
2021-008 SUBRECIPIENT MONITORING - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks Criteria Per 2 CFR section 200.332(b), a pass-through entity must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar awards, (2) the results of previous audits, (3) whether the subrecipient has new personnel or new or substantially changed systems, and (4) the extent and results of federal awarding agency monitoring. 2 CFR sections 200.332(d) through (f) require that the pass-through entity monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition/Cause The Authority passed through funds to one subrecipient under the emergency rental assistance program in 2021. Management did not perform a risk assessment or monitoring of the subrecipient during 2021. Effect The Authority is not in compliance with the subrecipient monitoring requirements of the program during 2021. Questioned Costs Less than $25,000. Context During 2021 the Authority paid $3,815,000 in passthrough funds to one subrecipient. A risk assessment was not performed, and monitoring activities did not occur in 2021 to determine if funds were properly spent. Repeat Finding No. Recommendation We recommend that the Authority develop a procedure/internal control to ensure a risk assessment is performed for all subrecipients, as required by 2 CFR section 200.332(b). Based on this risk assessment, appropriate monitoring procedures should be performed. Management Response See corrective action plan included in this report package.
Finding 2021-009 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring and Matching Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.303(a) - establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 200.331(b) - Requirements for Pass-Through Entities, states that all pass-through entities must assess the subrecipient’s risk of non-compliance with federal statutes, regulations, and terms and conditions of the subaward. 2 CFR 200.331(d) - establishes that the auditee must follow up and ensure subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided from the Pass Through Entity (PTE) detected through audits. 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. As part of monitoring the subrecipients, since there is a matching requirement within the grant, the CFSC’s procedures should monitor and ensure the subrecipients are complying the required match arrangements outlined in the subaward agreements. Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted. Monitoring of matching is not done each time expenditures are incurred by a subrecipient, which increases the risk that a subrecipient may not incur the required match costs before the end of the grant period. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not perform the following, which increases the risk of noncompliance: • Required risk assessments for the subrecipients, • Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any. • Ensure match expenditures are incurred throughout the duration of the grant period, which increases risk that CFSC may not meet its matching requirements through its subrecipients. Cause: CFSC’s procedures did not consistently ensure that the required risk assessments, monitoring, matching through subrecipients, or subrecipient follow-up were performed. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
2021-008 SUBRECIPIENT MONITORING - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks Criteria Per 2 CFR section 200.332(b), a pass-through entity must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar awards, (2) the results of previous audits, (3) whether the subrecipient has new personnel or new or substantially changed systems, and (4) the extent and results of federal awarding agency monitoring. 2 CFR sections 200.332(d) through (f) require that the pass-through entity monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition/Cause The Authority passed through funds to one subrecipient under the emergency rental assistance program in 2021. Management did not perform a risk assessment or monitoring of the subrecipient during 2021. Effect The Authority is not in compliance with the subrecipient monitoring requirements of the program during 2021. Questioned Costs Less than $25,000. Context During 2021 the Authority paid $3,815,000 in passthrough funds to one subrecipient. A risk assessment was not performed, and monitoring activities did not occur in 2021 to determine if funds were properly spent. Repeat Finding No. Recommendation We recommend that the Authority develop a procedure/internal control to ensure a risk assessment is performed for all subrecipients, as required by 2 CFR section 200.332(b). Based on this risk assessment, appropriate monitoring procedures should be performed. Management Response See corrective action plan included in this report package.
Finding 2021-009 Program: Office for Coastal Management Federal Financial Assistance Listing: 11.473 Federal Grantor: U.S. Department of Commerce Passed-through: National Fish and Wildlife Foundation Award No. and Year: 0318.19.070225 (2020) Compliance Requirements: Subrecipient Monitoring and Matching Type of Finding: Material Non-Compliance/Material Weakness Criteria: 2 CFR 200.303(a) - establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR Part 200.331(b) - Requirements for Pass-Through Entities, states that all pass-through entities must assess the subrecipient’s risk of non-compliance with federal statutes, regulations, and terms and conditions of the subaward. 2 CFR 200.331(d) - establishes that the auditee must follow up and ensure subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided from the Pass Through Entity (PTE) detected through audits. 2 CFR 200.332(d) - establishes that the auditee must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. As part of monitoring the subrecipients, since there is a matching requirement within the grant, the CFSC’s procedures should monitor and ensure the subrecipients are complying the required match arrangements outlined in the subaward agreements. Condition: CFSC did not perform risk assessment for all subrecipients selected for testing. CFSC was unable to provide supporting documentation to show that they inquired with the subrecipients about any audits they had undergone or evidence that CFSC received and reviewed audit reports to ensure timely follow ups were made if any findings pertaining to the Federal Award was noted. Monitoring of matching is not done each time expenditures are incurred by a subrecipient, which increases the risk that a subrecipient may not incur the required match costs before the end of the grant period. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions. Repeat Finding from Prior Year: Yes –2020-001 Effect: CFSC did not perform the following, which increases the risk of noncompliance: • Required risk assessments for the subrecipients, • Review subrecipient audit reports to ensure compliance with Federal Awards or make any necessary follow-ups pertaining to any findings noted, if any. • Ensure match expenditures are incurred throughout the duration of the grant period, which increases risk that CFSC may not meet its matching requirements through its subrecipients. Cause: CFSC’s procedures did not consistently ensure that the required risk assessments, monitoring, matching through subrecipients, or subrecipient follow-up were performed. Recommendation: We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required risk assessments are performed in accordance with the criteria outlined above. Views of Responsible Officials and Planned Corrective Actions: See Separate Corrective Action Plan.
Finding Number: 2021-005; Finding Type: Federal award finding; Federal Assistance Listing No.: 93.665; Pro-gram Name: COVID -19 Emergency Grants to Address Mental and Substance Use Disorders During COVID-19; Federal Agency: U.S. Department of Health and Human Services; Pass-Through Entity: Oregon Health Authority; Grant Number: 167045; Federal Award Year: 2021; Control Deficiency Type: Significant deficiency in internal controls over compliance; Instance of Noncompliance: Yes; Compliance Requirement: Subrecipient monitoring; Questioned Costs: None; Repeat Finding: No; Criteria: In accordance with the requirements of 2 CFR §200.332, a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all the required information at the time of the subaward so that federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Coalition did not include all of the required information in the subawards granted to subre-cipients. Information missing from the subaward grant agreements includes the following: Subrecipient unique entity identifier; Federal award date; Total amount of federal funds obligated to subrecipient including the current award; Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; Assistance listings number; the pass through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at the time of disburse-ment; Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414; All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in ac-cordance with federal statutes, regulations and the terms and conditions of the federal award. Cause: The coalition was unaware of the subaward requirements of CFR §200.332. Effect: The Coalition did not comply with CFR §200.332. Audit Recommendation: We recommend that management implement procedures to ensure that all subawards contain the information required by CFR §200.332. Management’s Response: The Coalition will ensure that all future federal subawards will contain the infor-mation required by CFR §200.332. All contracts, sub-grantees, and MOUs, will include information required.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-028 Federal Agency: U.S. Department of the Treasury AL Program: 21.019 Coronavirus Relief Fund Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $59,158 Criteria: In accordance with 2 CFR § 200.332, the pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. Subrecipient monitoring policies and procedures was not provided; as such, we did not obtain an understanding of CNMI’s process to identify subawards, evaluate risk of noncompliance, and perform monitoring procedures based upon identified risks. 2. Of one (or 100%) subrecipient tested, aggregating $59,158 of a total population of $5.097M, the subrecipient agreement was not provided and there was no evidence of monitoring procedures performed to determine whether the subrecipient is in compliance with applicable laws, regulations, and provisions of contracts and grant agreements, for which amount is questioned. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $59,158 result. Finding No. 2021-028, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.019 Coronavirus Relief Fund Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $59,158 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-033 Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $0 Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The CNMI has no existing written subrecipient monitoring policies and procedures. 2. Of one (or 100%) subrecipient tested, aggregating $541,495 of a total population of $11.4M, the subaward agreement was only executed on August 5, 2022, which was subsequent to when funds were disbursed to vendors. 3. Subsequent to FY 2021 and during our audit fieldwork was when the CNMI identified certain transactions to be beneficiaries in nature rather than as subrecipients. Accordingly, the CNMI revised its subrecipients listing from eleven to six amounting from $12,671,495 to $11,421,495. Cause: The CNMI lacks written subrecipient monitoring policies and procedures and lacks monitoring control procedures over distinctions between a beneficiary and a subrecipient. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as all transactions were processed and paid out through the central government. Finding No. 2021-033, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $0 Recommendation: The responsible CNMI personnel should consider obtaining training in the area of subrecipient distinction and establish written policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding Number: 2021-005; Finding Type: Federal award finding; Federal Assistance Listing No.: 93.665; Pro-gram Name: COVID -19 Emergency Grants to Address Mental and Substance Use Disorders During COVID-19; Federal Agency: U.S. Department of Health and Human Services; Pass-Through Entity: Oregon Health Authority; Grant Number: 167045; Federal Award Year: 2021; Control Deficiency Type: Significant deficiency in internal controls over compliance; Instance of Noncompliance: Yes; Compliance Requirement: Subrecipient monitoring; Questioned Costs: None; Repeat Finding: No; Criteria: In accordance with the requirements of 2 CFR §200.332, a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all the required information at the time of the subaward so that federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award. Condition: The Coalition did not include all of the required information in the subawards granted to subre-cipients. Information missing from the subaward grant agreements includes the following: Subrecipient unique entity identifier; Federal award date; Total amount of federal funds obligated to subrecipient including the current award; Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; Assistance listings number; the pass through entity must identify the dollar amount made available under each federal award and the Assistance Listings Number at the time of disburse-ment; Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414; All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in ac-cordance with federal statutes, regulations and the terms and conditions of the federal award. Cause: The coalition was unaware of the subaward requirements of CFR §200.332. Effect: The Coalition did not comply with CFR §200.332. Audit Recommendation: We recommend that management implement procedures to ensure that all subawards contain the information required by CFR §200.332. Management’s Response: The Coalition will ensure that all future federal subawards will contain the infor-mation required by CFR §200.332. All contracts, sub-grantees, and MOUs, will include information required.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-022 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The subrecipients of the Capital Improvement Projects (CIP) and Compact Impact programs did not match the listing per the SEFA. 2. The program did not include the following required information in the subrecipient agreements: • Subrecipient’s Data Universal Numbering System (DUNS) number; • Federal Award Identification Number (FAIN); • Subaward Period of Performance Start and End Date; • Amount of Federal Funds Obligated by this action; • Total Amount of Federal Funds Obligated to the subrecipient; and • Indirect cost rate for the Federal award. Finding No. 2021-022, continued Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D19AP00006 and D21AF10004 Area: Subrecipient Monitoring Questioned Costs: $ -0- Condition, continued: 3. There was no evidence of procedures used to monitor subrecipient compliance with applicable laws, regulations, and provisions of contracts and grant agreements. We are aware that the subrecipients, Public School System and Northern Marianas College, have been subjected to Single Audits; however, there is no evidence that the Single Audit reports were used as a monitoring tool. 4. Documentation was not provided to demonstrate monitoring procedures were performed on the subrecipients. Further, narrative reports on project status were not provided and made available. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as the Single Audit reports of the subrecipients tested have been issued with no findings noted. Identification as a Repeat Finding: Finding No. 2020-033 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-028 Federal Agency: U.S. Department of the Treasury AL Program: 21.019 Coronavirus Relief Fund Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $59,158 Criteria: In accordance with 2 CFR § 200.332, the pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. Subrecipient monitoring policies and procedures was not provided; as such, we did not obtain an understanding of CNMI’s process to identify subawards, evaluate risk of noncompliance, and perform monitoring procedures based upon identified risks. 2. Of one (or 100%) subrecipient tested, aggregating $59,158 of a total population of $5.097M, the subrecipient agreement was not provided and there was no evidence of monitoring procedures performed to determine whether the subrecipient is in compliance with applicable laws, regulations, and provisions of contracts and grant agreements, for which amount is questioned. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $59,158 result. Finding No. 2021-028, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.019 Coronavirus Relief Fund Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $59,158 Recommendation: The responsible personnel should consider obtaining training in the area of subrecipient monitoring and establishing and implementing policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
Finding No. 2021-033 Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $0 Criteria: In accordance with 2 CFR § 200.332, pass-through entity (PTE) must establish and implement subrecipient monitoring policies and procedures, including the following: • At the time of the award, clearly identifying to the subrecipient all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. • Evaluating the impact of subrecipient activities on the pass-through entity’s ability to comply with applicable federal regulations. Condition: 1. The CNMI has no existing written subrecipient monitoring policies and procedures. 2. Of one (or 100%) subrecipient tested, aggregating $541,495 of a total population of $11.4M, the subaward agreement was only executed on August 5, 2022, which was subsequent to when funds were disbursed to vendors. 3. Subsequent to FY 2021 and during our audit fieldwork was when the CNMI identified certain transactions to be beneficiaries in nature rather than as subrecipients. Accordingly, the CNMI revised its subrecipients listing from eleven to six amounting from $12,671,495 to $11,421,495. Cause: The CNMI lacks written subrecipient monitoring policies and procedures and lacks monitoring control procedures over distinctions between a beneficiary and a subrecipient. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements. No questioned costs are presented as all transactions were processed and paid out through the central government. Finding No. 2021-033, continued Federal Agency: U.S. Department of the Treasury AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Federal Award No.: COVID-19 Area: Subrecipient Monitoring Questioned Costs: $0 Recommendation: The responsible CNMI personnel should consider obtaining training in the area of subrecipient distinction and establish written policies and procedures over compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: The CNMI Corrective Action Plan states agreement.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job and Family Services. The Consortium should implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job and Family Services. The Consortium should implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job and Family Services. The Consortium should implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.
2 CFR § 2900.4 gives regulatory effect to the U.S. Department of Labor for 2 CFR § 200.332(a)(3) which requires a pass-through entity to impose any additional requirements on the subrecipient necessary 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. Additionally, Ohio Admin. Code 5101:9- 7-29 (D)(2)(c) requires WIOA local areas to submit the completed quarterly financial statement to the Bureau of County Finance and Technical Assistance (BCFTA) no later than the tenth calendar day of the second month following the quarter the report represents. Ohio Admin. Code 5101:9-7-29 further requires the fiscal agent to reconcile any difference between the WIOA local area's financial records and financial data submitted to BCFTA via CFIS. The following issues were noted related to the quarterly submissions: 1. The quarterly financial certification for the fourth quarter of calendar year 2018 was not filed until February 13, 2019, the third quarter of calendar year 2020 was not filed until at least November 17, 2020. Both of these were considered late filings. 2. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide system reports from their accounting system that reconciled to the actual financial data (i.e. beginning balances, revenues, expenses, ending balances) submitted to BCFTA via CFIS. Instead, for 2019 and 2020, the fiscal agent provided only manually maintained records of undetailed transactions to support the amounts they reported on the financial reports. Then for 2021, they provided nothing to support what was reported. 3. For all submissions in fiscal years 2019, 2020, and 2021, the fiscal agent was unable to provide any support for the amounts they reported as accruals on the certifications. This could lead to questions regarding accuracy of the amounts reported to Ohio Department of Job and Family Services. The Consortium should implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports should be supported by the accounting system of the Fiscal Agent.