2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that 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 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. Management’s Views and Corrective Action Plan Management’s response is included in “Management’s Views and Corrective Action Plan” included at the end of this report after the summary schedule of status of prior audit findings
U.S. Department of Health and Human Services Family Planning Services AL #93.217 Award No. FPHPA006563, FPHPA006619 Criteria: 2 CFR 200.331 requires that pass‐through entities disbursing federal funds to subrecipients have a formalized policy for identifying the subrecipient meets the applicable requirements, for evaluating risk, for monitoring subrecipient activity, and for ensuring accountability of For‐Profit Subrecipients, if applicable. Additionally, certain information regarding the federal award is required to be communicated to the subrecipient. During monitoring activities, the pass‐through entity is required to obtain the subrecipient’s audit reports so any findings can be evaluated by the pass‐through entity’s management. Condition: The Organization does not have a formalized policy. Additionally, the subrecipient agreements were missing required information and audit report findings were not reviewed and followed‐up on. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Effect: Certain compliance elements related to subrecipient monitoring were not met as a result of ineffective controls. Questioned Costs: None Context/Sampling: There were 11 subrecipients during the year, of which 3 were selected for review. Repeat Finding from Prior Year: No Recommendation: Management should implement a formal subrecipient monitoring policy using the guidance of 2 CFR 200.332 and update the subrecipient agreements to include all required information. Additionally, audit findings should be followed up on. Views of Responsible Officials: Management agrees with this finding.
2024-003 SUBRECIPIENT MONITORING – WOIA Federal agency: U.S. Department of Labor Federal Program Title & Assistance Listing Number: Workforce Investment Act Cluster - 17.258, 17.259, 17.578 Award Period: Program Year 2023-2024 Type of Finding: Material Weakness in Internal Control over Compliance; Material Non-compliance Compliance Areas: Subrecipient Monitoring Questioned Costs: None Condition During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring to such an extent that the Department has a modified opinion on this federal grant compliance area. The Department is currently behind on performing monitoring controls such as quarterly desk reviews, annual on-site evaluations, and remote reviewing and testing of cost documentation. The Department has not completed fiscal or programmatic monitoring relating to Program Year 2023-2024 activity for any of its subrecipients. Due to staffing vacancies at the beginning of the fiscal year, as of January 2024, the Department had fallen approximately 2 years behind. By fiscal year-end for 2024, they had just completed Program Year 2022-2023 monitoring, and are now beginning the next Program Year. This program of the Department lacked evidence that sufficient risk assessments of subrecipients were performed that would allow the Department to identify any potential deficiencies that would require follow-up. The Department asserted that risk assessments had been included as attachments to the subgrant agreements, although these were not provided to us. These attachments were intended to be self-assessments, rather than being performed by the Department itself. There was no provided evidence of Department scoring or performing an independent evaluation of these. Criteria §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: (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 passthrough 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. (3) 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. Effect The lack of internal controls over this compliance requirement provides an opportunity for federal grant noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. There is higher risk of material misstatement, fraud, noncompliance, or errors. This condition has caused the Department’s audit opinion over this grant’s compliance area to be modified. Cause The Department has not established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements. The Department has experienced staffing turnover during these time periods and training and monitoring is needed.
2024-003 SUBRECIPIENT MONITORING – WOIA Federal agency: U.S. Department of Labor Federal Program Title & Assistance Listing Number: Workforce Investment Act Cluster - 17.258, 17.259, 17.578 Award Period: Program Year 2023-2024 Type of Finding: Material Weakness in Internal Control over Compliance; Material Non-compliance Compliance Areas: Subrecipient Monitoring Questioned Costs: None Condition During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring to such an extent that the Department has a modified opinion on this federal grant compliance area. The Department is currently behind on performing monitoring controls such as quarterly desk reviews, annual on-site evaluations, and remote reviewing and testing of cost documentation. The Department has not completed fiscal or programmatic monitoring relating to Program Year 2023-2024 activity for any of its subrecipients. Due to staffing vacancies at the beginning of the fiscal year, as of January 2024, the Department had fallen approximately 2 years behind. By fiscal year-end for 2024, they had just completed Program Year 2022-2023 monitoring, and are now beginning the next Program Year. This program of the Department lacked evidence that sufficient risk assessments of subrecipients were performed that would allow the Department to identify any potential deficiencies that would require follow-up. The Department asserted that risk assessments had been included as attachments to the subgrant agreements, although these were not provided to us. These attachments were intended to be self-assessments, rather than being performed by the Department itself. There was no provided evidence of Department scoring or performing an independent evaluation of these. Criteria §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: (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 passthrough 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. (3) 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. Effect The lack of internal controls over this compliance requirement provides an opportunity for federal grant noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. There is higher risk of material misstatement, fraud, noncompliance, or errors. This condition has caused the Department’s audit opinion over this grant’s compliance area to be modified. Cause The Department has not established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements. The Department has experienced staffing turnover during these time periods and training and monitoring is needed.
2024-003 SUBRECIPIENT MONITORING – WOIA Federal agency: U.S. Department of Labor Federal Program Title & Assistance Listing Number: Workforce Investment Act Cluster - 17.258, 17.259, 17.578 Award Period: Program Year 2023-2024 Type of Finding: Material Weakness in Internal Control over Compliance; Material Non-compliance Compliance Areas: Subrecipient Monitoring Questioned Costs: None Condition During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring to such an extent that the Department has a modified opinion on this federal grant compliance area. The Department is currently behind on performing monitoring controls such as quarterly desk reviews, annual on-site evaluations, and remote reviewing and testing of cost documentation. The Department has not completed fiscal or programmatic monitoring relating to Program Year 2023-2024 activity for any of its subrecipients. Due to staffing vacancies at the beginning of the fiscal year, as of January 2024, the Department had fallen approximately 2 years behind. By fiscal year-end for 2024, they had just completed Program Year 2022-2023 monitoring, and are now beginning the next Program Year. This program of the Department lacked evidence that sufficient risk assessments of subrecipients were performed that would allow the Department to identify any potential deficiencies that would require follow-up. The Department asserted that risk assessments had been included as attachments to the subgrant agreements, although these were not provided to us. These attachments were intended to be self-assessments, rather than being performed by the Department itself. There was no provided evidence of Department scoring or performing an independent evaluation of these. Criteria §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: (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 passthrough 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. (3) 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. Effect The lack of internal controls over this compliance requirement provides an opportunity for federal grant noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. There is higher risk of material misstatement, fraud, noncompliance, or errors. This condition has caused the Department’s audit opinion over this grant’s compliance area to be modified. Cause The Department has not established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements. The Department has experienced staffing turnover during these time periods and training and monitoring is needed.
2024-004 SUBRECIPIENT MONITORING – AMERICORPS Federal agency: U.S. Corporation for National and Community Service Federal Program Title & Assistance Listing Number: AmeriCorps - 94.006 Award Period: Program Year 2023-2024 Type of Finding: Material Weakness in Internal Control over Compliance;Otherl Non-compliance Compliance Areas: Subrecipient Monitoring Questioned Costs: None Condition During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. The Department represented to us that annual site visits had been performed, but that there was no documentation related to those visits or the nature of the monitoring performed that could be provided as evidence. The extent of fiscal monitoring did not appear sufficient. There was no evidence of review of cost documentation for subrecipients who were not subject to heightened fiscal monitoring, other than summary-level reports and general ledger data. For subrecipients who were subject to heightened fiscal monitoring, one month of costs were selected for testing. The Department did not utilize an audit test sheet to record the results of these tests. Criteria §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: (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 passthrough 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. (3) 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. Effect The lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. There is higher risk of material misstatement, fraud, noncompliance, or errors. Cause The Department has not established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements. The Department has experienced staffing turnover during these time periods and training and monitoring is needed.
Criteria or Specific Requirement: 2 CFR section 200.332(b) requires pass-through entities to provide subrecipients with a subaward agreement and ensure that every subaward is clearly identified to the subrecipient as a subaward and provide specific information as outlined at 2 CFR section 200.332(b)(1) through (6). Condition: Internal controls over subrecipient monitoring do not appear to be effective. Testing procedures revealed that there was no subaward agreement provided to the subrecipient of grant funding. Context: There was only one subrecipient for this grant and there was no documentation of a subaward agreement being provided to the subrecepient. Questioned Costs: None Effect: The subrecipient may not have all of the required information that it needs for its own Uniform Guidance audit. In addition, the subrecipient may not be aware of the applicable laws and regulations as well as the specific compliance requirements as they relate to the funding they are receiving from the District. Cause: Because the subrecipient was involved with the application process and subsequent communications with the District as well as the Wisconsin Department of Workforce Development, the District thought the subrecipient had all of the required information and therefore didn't issue a formal subaward document. Repeat: No Auditor's Recommendation: We recommend that the District review its polices and procedures related to subrecipient monitoring. View of Responsible Officials: The finding is acknowledged. The District will provide a subaward agreement to the current subrecipient and has put in place the required subaward agreement on future federal grants with subrecipients to ensure compliance with the Uniform Guidance requirements.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
Criteria: The Uniform Guidance Federal regulations per 2 CFR section 200.332 requires among other things, that all requirements be imposed by the pass-through entity (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. Universe/Population: The portion of federal expenditures reimbursed and passed through to subrecipients by the East Baton Rouge Parish Sheriff’s Office (the Sheriff). Based on these requirements, the population consisted of a total dollar amount of $205,788. Condition: Funding passed down to subrecipients of the federal program are not adequately reviewed for all applicable compliance requirements as required under the Uniform Guidance. We noted that for the subrecipient a grant accountant reviewed the expenditures for allowable activities and allowable costs, however these costs were not reviewed for appropriate federal procurement and reporting requirements. Cause: The Sheriff does not currently have an adequate control designed and implemented to test the expenditures being reimbursed for various award requirements as required under the Uniform Guidance over subrecipient monitoring policies, to a sufficient level of detail and understanding. Effect: Without accurate review of the costs being submitted for reimbursement, the Sheriff could request for reimbursement costs that are unallowable or did not follow the appropriate federal guidelines for reimbursement. The amount of questioned costs is $205,788. Recommendation: The Sheriff should review subrecipient costs for all grant requirements before being submitted for reimbursement to ensure appropriate monitoring. This review should also include review of subrecipient quarterly reports. View of Responsible Official: Management agrees with this finding and will implement a more detailed review process for PTE and subrecipient monitoring requirements to ensure grant requirements are being appropriately followed.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.
2024-001 – Subrecipient Monitoring Federal Program: Refugee and Entrant Assistance Program Federal Agency: U.S. Department of Health and Human Services Assistance Listing Number: 93.566 Repeat of Prior Finding: Yes, initial finding during fiscal year 2023. Finding 2023-006. Type of Finding: Noncompliance and Material Weakness in Internal Controls Over Compliance Criteria According to 2 CFR §200.331, a pass-through entity must adhere to the provisions in 2 CFR §200.332 which require passthrough entities to perform certain subrecipient monitoring procedures. These procedures include providing the subrecipient necessary award information so that the federal award is used in accordance with federal regulations, evaluating risks of noncompliance of subrecipients, implementing monitoring procedures based upon identified risks, and, if applicable, obtaining a copy of the subrecipients’ annual audit, and taking appropriate action on deficiencies detected through the audits, as well as other requirements. Additionally, the nonfederal entity must establish and maintain effective internal controls over the federal award to provide reasonable assurance that the non-federal entity is managing the award in compliance with federal regulations. Further, according to 2 CFR §200.331(a), specific information must be explicitly included in agreements with subrecipients that includes but is not limited to providing the Assistance Listing number, whether funding is COVID related, and that the subrecipient is responsible for compliance with 2 CFR §200 including Subpart F, if applicable. Condition and Context The Organization did not have procedures and adequate internal controls in place during the fiscal year to ensure the terms and conditions of the subaward required by 2 CFR §200.332 were provided to the subrecipient in a timely manner prior to disbursing the federal funds. Cause The Organization lacked a formal process during the fiscal year for providing subaward agreements or written notifications to subrecipients regarding federal award terms and conditions in accordance with applicable regulations prior to awarding the subaward. Effect or Potential Effect Without providing the subrecipient with details on the subaward as required at the time the subaward is made, subrecipients may be unaware that their award is subject to federal compliance requirements. Questioned Costs None noted. Recommendations We recommend developing and implementing formal procedures to ensure all subrecipients are provided with a written subaward agreement or equivalent documentation stating the required award details at the time of the subaward. Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and recommendations. See the attached corrective action plan.