2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that 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 described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that 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 described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that 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 described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.
Federal Agency: Department of Health and Human Services Federal Program Name: HeadStart Assistance Listing Number: 93.600 Federal Award Identification Number and Year: 03CH011220-04-00, 2023 03CH011220-05-00, 2024 Award Period: 9/1/2022-8/31/2023 9/1/2023-8/31/2024 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or Specific Requirement: Compliance: Per 2 CFR 200 § 200.332(a)1 (d) a non-Federal entity should 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. Internal Control: Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Community and Human Services (DCHS) did not provide documentation to support monitoring of the subrecipient’s activities. Questioned Costs: None Context: DCHS has one sub awardee and issued a subaward in the amount of $2,822,089. Cause: DCHS’ procedures did not maintain supporting documentation of subrecipient monitoring activities. Effect: DCHS was unable to provide evidence they were in compliance with subrecipient monitoring requirements. Repeat Finding: No Recommendation: We recommend that DCHS enhance procedures to ensure that sub recipient monitoring activities are documented, and evidence of compliance readily available for review. Views of Responsible Officials: There is no disagreement with the audit finding and new personnel in the Department of Community and Human Services will ensure that all required monitoring is performed and documented in a timely manner.
Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) Criteria: Per 2 CFR sections 200.332(d) through (f), a pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves the performance goals. Per 2 CFR section 200.502(a), the determination of when a Federal award is expended must be based on when the activity related to the Federal award occurs which is generally expenditure/expense transactions associated with awards. Condition: During our testing over subrecipient monitoring, the County was unable to provide subrecipient monitoring support. Questioned Costs: None Context: We selected 8 samples as part of our testing over Subrecipient Monitoring. Of the 8 samples selected, the County was unable to provide adequate support for the subrecipients selected. Cause: The County has policies that require departments to conduct subrecipient monitoring to ensure compliance with grant requirements. However, the policy does not include documentation of these monitoring activities, such as site visits, financial reviews, or performance evaluations. This lack of documentation results in an inability to verify that subrecipient monitoring is being performed effectively and consistently. Effect: Without proper oversight, subrecipients may fail to achieve program goals and objectives, leading to poor performance and outcomes for the funded programs. Repeat Finding: No Recommendation: We recommend that the County implement procedures to ensure that federal guidance is followed related to subrecipient monitoring and provide trainings on these procedures, including maintaining documentation of the review performed by the County. View of Responsible Officials: There is no disagreement with the audit finding.
Congressional Directives, ALN 93.493, U.S. Department of Health and Human Services Applicable Institution: University of Mississippi Medical Center (UMMC) Congressional Directives, ALN 95.010, Executive Office of the President Applicable Institution; University of Mississippi (UM) Program Year 2023-2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement – Subrecipient Monitoring (31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.332, and 200.501(h); federal awarding agency regulations; and the terms and conditions of the award. Condition – The pass-through entity must identify the award and applicable requirements, including whether the grant is considered research and development (R&D). Subawards were made that identified the grants as R&D when they were not. Cause – The institution’s internal controls did not ensure the applicable requirements were communicated to the subrecipient. Effect or Potential Effect – The subaward was or could have been improperly classified as R&D on the subrecipients’ schedule of expenditures of federal awards. Questioned costs – None Context – ALN 93.493 - Out of 3 subrecipients, a sample of 1 was selected for testing, ALN 95.010 – Out of 7 subrecipients, a sample of 2 were selected for testing. Our sample was not, and was not intended to be, statistically valid. All awards tested communicated that the subaward was R&D. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The institutions should update policies and procedures to ensure the award and applicable requirements are communicated to subrecipients. Views of Responsible Officials and Planned Corrective Actions – There is no disagreement with the audit finding. See corrective action plan.
Congressional Directives, ALN 93.493, U.S. Department of Health and Human Services Applicable Institution: University of Mississippi Medical Center (UMMC) Congressional Directives, ALN 95.010, Executive Office of the President Applicable Institution; University of Mississippi (UM) Program Year 2023-2024 Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or Specific Requirement – Subrecipient Monitoring (31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.332, and 200.501(h); federal awarding agency regulations; and the terms and conditions of the award. Condition – The pass-through entity must identify the award and applicable requirements, including whether the grant is considered research and development (R&D). Subawards were made that identified the grants as R&D when they were not. Cause – The institution’s internal controls did not ensure the applicable requirements were communicated to the subrecipient. Effect or Potential Effect – The subaward was or could have been improperly classified as R&D on the subrecipients’ schedule of expenditures of federal awards. Questioned costs – None Context – ALN 93.493 - Out of 3 subrecipients, a sample of 1 was selected for testing, ALN 95.010 – Out of 7 subrecipients, a sample of 2 were selected for testing. Our sample was not, and was not intended to be, statistically valid. All awards tested communicated that the subaward was R&D. Identification as a Repeat Finding, if Applicable – N/A Recommendation – The institutions should update policies and procedures to ensure the award and applicable requirements are communicated to subrecipients. Views of Responsible Officials and Planned Corrective Actions – There is no disagreement with the audit finding. See corrective action plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued) Ref. No. 2024-005 Subrecipient Monitoring - Significant Deficiency Federal agency: Department of Treasury Pass-Through Entity: State of Hawaii Program: ALN No. 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Repeat Finding? Yes; 2023-005 Criteria: Subrecipient monitoring and management requirements for pass-through entities at 2 CFR §200.332 - Requirements for pass-through entities require that the County: • Evaluate each subrecipient’s fraud risk and risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward [2 CFR § 200.332(c)]. • Verify that subrecipients are audited as required by 2 CFR Part 200, Subpart F - Audit Requirements if the entity expended $750,000 or more during the entity’s fiscal year [2 CFR § 200.332(g)]. As part of the County’s policies and procedures to evaluate subrecipient risk and to determine whether or not the subrecipient is subject to an audit as required by 2 CFR Part 200, Subpart F - Audit Requirements, subrecipients are required to complete the “Subrecipient Monitoring and Risk Assessment Form” which is to be submitted along with the subrecipient’s grant application or prior to the execution of the grant agreement, upon award. Condition: During our testing of the subrecipient monitoring compliance requirement, we discovered three (3) out of 3 samples tested where the County did not complete the Subrecipient Monitoring and Risk Assessment Form. Cause: The County did not follow its policies and procedures over subrecipient monitoring throughout the fiscal year. Effect: Completion of the Subrecipient Monitoring and Risk Assessment Form for subrecipients help ensure proper accountability and compliance with program requirements and achievement of performance goals. Questioned Cost: $ -- Recommendation We recommend the County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 Views of Responsible Officials and Planned Corrective Action The County agrees with the finding and the recommendation. See Part IV Corrective Action Plan.
Reference Number: 2024-002 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2023-24 Name of Department: County Executive Office Department of Aging Department of Arts and Culture Department of Economic Opportunity Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance; Material Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(e), all pass-through entities (PTE) must: Monitor the activities of the subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notification from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue management decision for audit findings pertaining to only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Condition During our audit of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, we selected fifteen (15) subrecipients with active contracts with the County during FY 2023-24. We noted for seven (7) contracts administered by the Departments of Aging, Arts and Culture, and Economic Opportunity, the departments did not perform subrecipient monitoring related to the CSLFRF program during FY 2023-24. This is a repeat finding of 2023-009. Cause Due to the urgency to implement the CSLFRF program, the departments needed more time to enter into contracts with independent CPA firms to monitor the CSLFRF subrecipients and document the reviews in accordance with subrecipient monitoring requirements. Effect Failure to document monitoring results in noncompliance with the subrecipient monitoring requirements 2 CFR § 200.332(e). Questioned Costs Questioned costs were not determinable. Context Of the fifteen (15) subrecipients selected for testing, which totaled $20,981,306, from a population of 76 subrecipients with expenditures totaling $101,950,949, the departments did not perform subrecipient monitoring for seven (7) subrecipients with expenditures totaling $19,118,116. The sample was not a statistically valid sample. Recommendation We recommend the County monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and maintain sufficient records of monitoring subrecipients in accordance with subrecipient monitoring requirements.
Reference Number: 2024-002 Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Federal Assistance Listing Number: 21.027 Federal Agency: U.S. Department of Treasury Pass-Through Entity: N/A Federal Award Number and Year: Fiscal Year 2023-24 Name of Department: County Executive Office Department of Aging Department of Arts and Culture Department of Economic Opportunity Category of Finding: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance; Material Noncompliance Criteria In accordance with Title 2 U.S. Code of Federal Regulations (CFR) § 200.332(e), all pass-through entities (PTE) must: Monitor the activities of the subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notification from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue management decision for audit findings pertaining to only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient’s cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section § 200.513(a)(4)(viii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Condition During our audit of the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) program, we selected fifteen (15) subrecipients with active contracts with the County during FY 2023-24. We noted for seven (7) contracts administered by the Departments of Aging, Arts and Culture, and Economic Opportunity, the departments did not perform subrecipient monitoring related to the CSLFRF program during FY 2023-24. This is a repeat finding of 2023-009. Cause Due to the urgency to implement the CSLFRF program, the departments needed more time to enter into contracts with independent CPA firms to monitor the CSLFRF subrecipients and document the reviews in accordance with subrecipient monitoring requirements. Effect Failure to document monitoring results in noncompliance with the subrecipient monitoring requirements 2 CFR § 200.332(e). Questioned Costs Questioned costs were not determinable. Context Of the fifteen (15) subrecipients selected for testing, which totaled $20,981,306, from a population of 76 subrecipients with expenditures totaling $101,950,949, the departments did not perform subrecipient monitoring for seven (7) subrecipients with expenditures totaling $19,118,116. The sample was not a statistically valid sample. Recommendation We recommend the County monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes and maintain sufficient records of monitoring subrecipients in accordance with subrecipient monitoring requirements.
2024-005 SUBRECIPIENT MONITORING Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants – Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants – 97.042 Homeland Security Grant Program – 97.067 Award Period: Various Type of Finding:Significant Deficiency in Internal Control over Compliance Other Non-compliance Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. . ALN 97.036, ALN 97.042, ALN 97.067 The Department lacked an effective process to timely provide documentation to the auditors which would evidence compliance with the Subrecipient Monitoring compliance requirement. This makes it difficult for management to monitor for compliance or for a third party to test compliance. All requested documentation was ultimate provided. ALN 97.036 o We reviewed files for 5 subrecipients, from which there were 16 ongoing projects during fiscal year 2024. Of these, 1 of 5 subrecipients did not have evidence that a risk assessment was performed. 2 of 5 subrecipients did not have adequate documentation of monitoring activities performed, including the Department's monitoring checklist. Management's Progress for Repeated Finding: Management made some progress in the performing of risk assessments and reviews of audits for non-disaster grants, but still has opportunity to improve controls in the areas described above. Criteria: According to §200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass- through entity detected through audits, on-site reviews, and 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. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department's sub- grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department's approved sub-recipients for monitoring purposes and risk designation.
2024-005 SUBRECIPIENT MONITORING Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants – Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants – 97.042 Homeland Security Grant Program – 97.067 Award Period: Various Type of Finding:Significant Deficiency in Internal Control over Compliance Other Non-compliance Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. . ALN 97.036, ALN 97.042, ALN 97.067 The Department lacked an effective process to timely provide documentation to the auditors which would evidence compliance with the Subrecipient Monitoring compliance requirement. This makes it difficult for management to monitor for compliance or for a third party to test compliance. All requested documentation was ultimate provided. ALN 97.036 o We reviewed files for 5 subrecipients, from which there were 16 ongoing projects during fiscal year 2024. Of these, 1 of 5 subrecipients did not have evidence that a risk assessment was performed. 2 of 5 subrecipients did not have adequate documentation of monitoring activities performed, including the Department's monitoring checklist. Management's Progress for Repeated Finding: Management made some progress in the performing of risk assessments and reviews of audits for non-disaster grants, but still has opportunity to improve controls in the areas described above. Criteria: According to §200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass- through entity detected through audits, on-site reviews, and 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. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department's sub- grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department's approved sub-recipients for monitoring purposes and risk designation.
2024-005 SUBRECIPIENT MONITORING Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants – Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants – 97.042 Homeland Security Grant Program – 97.067 Award Period: Various Type of Finding:Significant Deficiency in Internal Control over Compliance Other Non-compliance Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. . ALN 97.036, ALN 97.042, ALN 97.067 The Department lacked an effective process to timely provide documentation to the auditors which would evidence compliance with the Subrecipient Monitoring compliance requirement. This makes it difficult for management to monitor for compliance or for a third party to test compliance. All requested documentation was ultimate provided. ALN 97.036 o We reviewed files for 5 subrecipients, from which there were 16 ongoing projects during fiscal year 2024. Of these, 1 of 5 subrecipients did not have evidence that a risk assessment was performed. 2 of 5 subrecipients did not have adequate documentation of monitoring activities performed, including the Department's monitoring checklist. Management's Progress for Repeated Finding: Management made some progress in the performing of risk assessments and reviews of audits for non-disaster grants, but still has opportunity to improve controls in the areas described above. Criteria: According to §200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass- through entity detected through audits, on-site reviews, and 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. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department's sub- grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department's approved sub-recipients for monitoring purposes and risk designation.
Finding Reference Number: 2024-005 NH Fish and Game Department Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02 Federal Award Year: 2022, 2023 U.S. Department of Interior Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. This would include internal controls related to the cash management process. Condition During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following: A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated: • Subrecipient's unique entity identifier • Identification of whether the Federal award is for research and development B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following: • For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed. • For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire. As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment. C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement. D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report. As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project. E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued. Cause The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented. View of Responsible Officials: Management partially concurs with this finding. Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-005 NH Fish and Game Department Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02 Federal Award Year: 2022, 2023 U.S. Department of Interior Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. This would include internal controls related to the cash management process. Condition During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following: A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated: • Subrecipient's unique entity identifier • Identification of whether the Federal award is for research and development B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following: • For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed. • For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire. As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment. C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement. D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report. As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project. E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued. Cause The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented. View of Responsible Officials: Management partially concurs with this finding. Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-005 NH Fish and Game Department Fish and Wildlife Cluster (Assistance Listing #15.605, #15.611, #15.626) Federal Award Numbers: F22AF00995-00, F22AF00929-00, F23AF03086-00, F22AF00514-01, F22AF02616-02 Federal Award Year: 2022, 2023 U.S. Department of Interior Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements - Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. This would include internal controls related to the cash management process. Condition During the year ended June 30, 2024, the New Hampshire Fish and Game Department (the Department) passed through $484,952 of federal funding to 1 subrecipient to fund 4 different projects. As part of our testwork related subrecipient monitoring, we identified the following: A. The Department communicates award information through the approved grant agreement. For 3 of 4 projects selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR 200.332(b). Specifically, the following elements were not communicated: • Subrecipient's unique entity identifier • Identification of whether the Federal award is for research and development B. As part of the during the award monitoring testwork, we noted that the Department completes a risk assessment questionnaire for all new projects they approve for the subrecipient. As part of our testwork over the risk assessments performed, we identified the following: • For 1 of 4 projects selected for testwork, there was no risk assessment questionnaire completed. • For 3 of 4 projects selected for testwork, a risk assessment questionnaire was completed, however there were no required monitoring procedures outlined within the questionnaire. As a result, we were not able to determine what monitoring procedures should have been performed over the projects as a result of the risk assessment. C. The Department’s during the award monitoring includes the review and approval of the subrecipient’s request for reimbursement. During our testwork over the review and approval of the request for reimbursement, we noted that for all 9 invoices selected for testwork, that while the invoice appeared to be properly reviewed and approved, the level of detail included within the invoice would not allow the Department to determine the reasonableness of the costs incurred to ensure that they were incurred in accordance with the grant agreement. D. The Department’s during the award monitoring includes obtaining a progress report related to each project that the subrecipient has been granted funding for. As part of our testwork, we identified that for all 4 projects selected for testwork, while a progress report was obtained, there was no evidence provided to support that the Department had reviewed the report. As a result, we were unable to determine based on the Department’s risk assessment procedures what the type and frequency of monitoring procedures that should have been performed over each project. E. The Department does not have formal policies and procedures to review and maintain documentation to evidence the review and approval of the subrecipient’s unform guidance report. There was no documentation to support that the Department had obtained and reviewed its subrecipient’s most recent uniform guidance report issued. Cause The cause of the condition found was primarily due to a lack of formal written policies and procedures and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that all subrecipient grant agreements contains all required communications, that a risk assessment is performed that will outline the types and frequency of monitoring procedures to be performed, that all during the award monitoring activities are properly documented and that the receipt and review of the subrecipient’s uniform guidance report is properly documented. View of Responsible Officials: Management partially concurs with this finding. Rejoinder: As documented within the condition found, sufficient documentation was not provided to demonstrate that the Department complied with 2 CFR section 200.332(a), 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h).
Finding Reference Number: 2024-17 NH Department of Health and Human Services Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053) Federal Award Number: 2401NHOASS, 2301NHOASS Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed. B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed. D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely. Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17 NH Department of Health and Human Services Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053) Federal Award Number: 2401NHOASS, 2301NHOASS Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed. B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed. D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely. Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17 NH Department of Health and Human Services Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053) Federal Award Number: 2401NHOASS, 2301NHOASS Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed. B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed. D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely. Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17 NH Department of Health and Human Services Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053) Federal Award Number: 2401NHOASS, 2301NHOASS Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed. B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed. D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely. Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-17 NH Department of Health and Human Services Aging Cluster and COVID-19 Aging Cluster (Assistance Listing #93.044, #93.045, #93.053) Federal Award Number: 2401NHOASS, 2301NHOASS Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $9,048,291 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 2 of 7 subrecipients selected for testwork, a risk assessment was not completed. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. There was no documentation provided that any monitoring procedures were performed. B. For 2 of 7 subrecipients selected for testwork, a transportation risk assessment was completed. Per review of the risk assessment, a quarterly review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided that this review had taken place. In addition, a nutrition risk assessment was also completed, however there were no specified monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. C. For 1 of 7 subrecipients selected for testwork, a nutrition risk assessment was completed. Based on our review of the risk assessment, a review was to be performed to examine the expenditure detail to assess purchasing compliance with contract requirements and applicable laws or rules. There was no documentation provided to support that this type of monitoring procedure was performed. D. For 1 of 7 subrecipients selected for testwork, the nutrition risk assessment that was completed did not contain any required monitoring procedures. As such, we are unable to determine if the appropriate monitoring procedures were performed for this subrecipient. E. For 1 of 7 subrecipients selected for testwork the nutrition risk assessment indicated that an onsite review should be performed annually. The risk assessment was dated July 19, 2023 and as of June 30, 2024 an on-site monitoring review was not completed. We further noted that a review was conducted in October of 2024. As the risk assessment indicated the review was to be conducted annually, it does not appear that this review was completed timely. Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-020 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-011 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $3,241,196 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. We were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not contain any suggested monitoring procedures. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As no further monitoring procedures were performed by the Department to ensure that the subrecipient was in compliance with the terms and conditions of its subrecipient grant agreement, the Department does not appear to have monitoring procedure in place that would allow it to timely identify noncompliance incurred at the subrecipient level. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the subrecipient risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, particularly if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-020 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-011 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $3,241,196 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. We were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not contain any suggested monitoring procedures. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As no further monitoring procedures were performed by the Department to ensure that the subrecipient was in compliance with the terms and conditions of its subrecipient grant agreement, the Department does not appear to have monitoring procedure in place that would allow it to timely identify noncompliance incurred at the subrecipient level. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the subrecipient risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, particularly if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-021 NH Department of Energy Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2301NHLIEA, 2401NHLIEA Federal Award Year: 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-015 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity must: • Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); • Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2024, $38,545,693 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 4 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) b. Identification of whether the award is R&D B. The data that is used to compile the Annual Report on Households Assisted by LIHEAP is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that award information is appropriately communicated and that there is appropriate monitoring procedures performed over the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Effect The effect of the condition found is that the Department did not comply with section 2 CFR 200.332 (a) and 2 CFR 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that all required award identification information is communicated to subrecipients and over the monitoring of data submitted by subrecipients to be used in the Annual Report on Households Assisted by LIHEAP to ensure that the report is complete and accurate. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025 NH Department of Health and Human Services CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596) Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD Federal Award Year: 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period. C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025 NH Department of Health and Human Services CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596) Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD Federal Award Year: 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period. C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-025 NH Department of Health and Human Services CCDF Cluster COVID-19 CCDF Cluster (Assistance Listing #93.575, #93.596) Federal Award Number: 2101NHCDC6, 2201NHCCDD, 2301NHCCDD Federal Award Year: 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,770,973 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 1 of 3 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. B. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a quarterly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period. C. For 1 of 3 of subrecipients selected for testwork, the risk assessment indicated that a monthly expenditure review was to be performed. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-026 NH Department of Health and Human Services Opioid STR (Assistance Listing #93.788) Federal Award Number: H79TI081685, H79TI083326, H79TI085759 Federal Award Year: 2022, 2023, 2024 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements –Clearly identify to the subrecipient the award as a subrecipient by providing the information prescribed in 2 CFR 200.332(a) 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $21,190,358 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. For 3 of 7 subrecipients selected for testwork, per review of the award communication, the Department did not properly communicate the indirect cost rate for the federal award. B. For 1 of 7 subrecipients selected for testwork, there were no suggested monitoring procedures included within the subrecipient’s risk assessment. As a result, we were unable to determine if the Department had adequately monitored the subrecipient. We noted that while there no monitoring procedures listed, the Department did complete a monthly expenditure detail review. C. For 1 of 7 subrecipients selected for testwork, the risk assessment indicated that an annual onsite monitoring review was to be conducted. We were unable to obtain documentation to support that an onsite monitoring review was completed or started during our audit period. Cause The cause of the condition found was primarily due to a lack of formal documented policies, procedures and internal controls to ensure that the required award identification information is communicated to all subrecipients and to ensure that required monitoring procedures outlined within the subrecipient’s risk assessment is performed. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a), 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). This would ensure that all required award identification information is properly communicated to subrecipients, and that the prescribed monitoring procedures outlined within the risk assessment are properly performed. Written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder: As documented in Bullet B above, the risk assessment provided by the Department for 1 of 7 subrecipients did not contain any suggested monitoring procedures. As a result, we were unable to determine if the Department had adequately monitored the subrecipient.
Finding Reference Number: 2024-028 NH Department of Health and Human Services Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959) Federal Award Numbers: 1B08TI084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-017 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,698,389 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified that for all 9 of the subrecipients selected for testwork, the risk assessment indicated that on a monthly an examination of the expenditure detail to assess purchasing compliance with contract requirements and applicable laws and regulations was to be performed. As part of our testwork, we were unable to obtain documentation to support that this review had taken place. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b) and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-028 NH Department of Health and Human Services Block Grants for Substance Use Prevention, Treatment, and Recovery Services and COVID-19 Block Grants for Substance Use Prevention, Treatment, and Recovery Services (Assistance Listing #93.959) Federal Award Numbers: 1B08TI084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-017 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2024, the New Hampshire Department of Health and Human Services (the Department) passed through $7,698,389 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified that for all 9 of the subrecipients selected for testwork, the risk assessment indicated that on a monthly an examination of the expenditure detail to assess purchasing compliance with contract requirements and applicable laws and regulations was to be performed. As part of our testwork, we were unable to obtain documentation to support that this review had taken place. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b) and 2 CFR sections 200.332(d) through (f). Questioned Costs: None. Recommendation We recommend the Department develop written policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), and 2 CFR sections 200.332(d) through (f). In addition, written policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-023 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: • Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and • Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures. C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year. • For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report. Cause The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs: None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2024-034 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2023-023 Statistically Valid Sample: The sample was not intended to be, and was not, a statistically valid sample. Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 2 CFR 200.303 (a) states that non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2024, $41,851,050 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 17 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: • Identification of whether the award is R&D was not communicated for 13 of 17 subrecipients selected for testwork; and • Indirect cost rate for the federal award was not communicated for 13 of 17 subrecipients selected for testwork B. For 4 of 17 subrecipients selected for testwork, while a risk assessment was performed, the Department did not perform it within calendar year of when the award was obligated as outlined within their policies and procedures. C. For 1 of 17 subrecipients selected for testwork, the risk assessment form was not dated or initialed to indicted when the risk assessment procedures were performed. As such, it was unclear if the risk assessment was completed timely. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no uniform guidance report review policies and procedures in place. For the 17 subrecipients selected for testwork, 5 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 4 of 5 subrecipients, the subrecipient’s uniform guidance report was not reviewed due to updated risk assessments not being performed in the current year. • For 1 of 5 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report. Cause The cause of the condition found was primarily due to the Department not following their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs: None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Reference Number: 2024-014 Prior Year Finding: 2023-025 Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Human Services Federal Program: Opioid STR Assistance Listing Number: 93.788 Award Number and Year: H79T1083317 (9/3/2020 – 9/29/2023), H79T1085743 (9/30/2022 – 9/29/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Control – Per 2 CFR section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Department of Human Services (Department) did not include all required information in subaward agreements. Context: For 1 of 13 subawards selected for testing, the subrecipient’s unique identifier and the Federal Award Identification Number (FAIN) were omitted from the subaward agreement. Questioned costs: None noted. Cause: The Department’s procedures were not effective to ensure that subawards were issued in compliance with Federal requirements. Internal controls did not prevent or detect the errors. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Recommendation: The Department should review and enhance internal controls and procedures to ensure that all required information is included in subaward agreements. Views of responsible officials: DMHAS acknowledges that the FAIN was omitted in a single notice of sub recipient award that predates the implementation date of its FY 2023 Corrective Action Plan (CAP). The award at issue relates to a “special County” add-on contract (one (1) of a total of nineteen (19)) that is tracked manually and in the DMHAS Contract Information Management System (CIMS) on which it currently relies to relay the data components required by 2 CFR 200.332. The single omission of the FAIN was due to a clerical error, whereby CIMS was not updated consistent with the manual record of the 2024 County contract renewal. DMHAS acknowledged in its FY 2023 CAP that CIMS was being replaced with SAGE in order to automate sub recipient notices, reduce administrative burden and decrease clerical errors that result from manual data entry. DMHAS notes that the original 2025 SAGE go-live date has been delayed and moved to Summer 2026. Therefore, DMHAS made improvements to CIMS (that is available to Providers). In addition to identifying the federal funding source in the program column and in the notes, CIMS now includes a federal drop down box that links the federal NOAs to the subrecipient agreement. DMHAS is compliant with its FY 2023 CAP which included a July 1, 2024 implementation date. Beginning July 1, 2024, DMHAS starting using a new Subaward template that includes the requisite data elements. DMHAS created a contract policy update and completed template trainings in-person and remotely. The DMHAS Compliance Unit audited the use of the new template to ensure Subaward include the requisite data elements.
2024-008 - Noncompliance with Subrecipient Monitoring Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2019 - 2023 Award Numbers: DE-EE0009421, FA9550-21-1-0215, M19AC00015, OIA-1920858, OIA-2019511, OIA-2119688, U19AI142636 Compliance Requirement: Subrecipient Monitoring Repeat Finding: Yes (Prior Year Finding No. 2023-008) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, UL Lafayette did not adequately monitor subrecipients of the Research and Development (R&D) Cluster Programs. In a non-statistical sample of seven subawards out of a population of 50 subawards, it was noted that for six (85.7%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the financial and performance reports required by the subaward agreement were obtained and reviewed by UL Lafayette. For three (42.9%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients’ fraud risk and risk of noncompliance with federal regulations and the terms of the subaward. For two of the subrecipients reviewed (28.6%), UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit and that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for one (14.3%) of the subrecipients evaluated, the subaward documents did not contain the federal award date as required by federal regulations. Criteria: Per 2 CFR 200.332(b)(1)(iv), all pass-through entities must ensure that every subaward includes the federal award date. 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient's fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. 2 CFR 200.332(e)(1) requires that pass-through monitoring include reviewing financial and performance reports required by the pass-through entity. 2 CFR 200.332(e)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings, in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient’s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings. Per 2 CFR 200.332(g), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient’s fiscal year. Cause: UL Lafayette did not have sufficient controls in place to adequately monitor subrecipients as required by federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency. Recommendation: UL Lafayette should strengthen controls to ensure that all required financial and performance reports are obtained and reviewed and that all required subrecipient audit reports are obtained and reviewed in order to evaluate the impact of any findings noted by the audit and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure that required information is included in the subaward documents and that risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-64).
2024-008 - Noncompliance with Subrecipient Monitoring Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2019 - 2023 Award Numbers: DE-EE0009421, FA9550-21-1-0215, M19AC00015, OIA-1920858, OIA-2019511, OIA-2119688, U19AI142636 Compliance Requirement: Subrecipient Monitoring Repeat Finding: Yes (Prior Year Finding No. 2023-008) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, UL Lafayette did not adequately monitor subrecipients of the Research and Development (R&D) Cluster Programs. In a non-statistical sample of seven subawards out of a population of 50 subawards, it was noted that for six (85.7%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the financial and performance reports required by the subaward agreement were obtained and reviewed by UL Lafayette. For three (42.9%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients’ fraud risk and risk of noncompliance with federal regulations and the terms of the subaward. For two of the subrecipients reviewed (28.6%), UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit and that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for one (14.3%) of the subrecipients evaluated, the subaward documents did not contain the federal award date as required by federal regulations. Criteria: Per 2 CFR 200.332(b)(1)(iv), all pass-through entities must ensure that every subaward includes the federal award date. 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient's fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. 2 CFR 200.332(e)(1) requires that pass-through monitoring include reviewing financial and performance reports required by the pass-through entity. 2 CFR 200.332(e)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings, in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient’s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings. Per 2 CFR 200.332(g), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient’s fiscal year. Cause: UL Lafayette did not have sufficient controls in place to adequately monitor subrecipients as required by federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency. Recommendation: UL Lafayette should strengthen controls to ensure that all required financial and performance reports are obtained and reviewed and that all required subrecipient audit reports are obtained and reviewed in order to evaluate the impact of any findings noted by the audit and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure that required information is included in the subaward documents and that risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-64).
2024-008 - Noncompliance with Subrecipient Monitoring Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2019 - 2023 Award Numbers: DE-EE0009421, FA9550-21-1-0215, M19AC00015, OIA-1920858, OIA-2019511, OIA-2119688, U19AI142636 Compliance Requirement: Subrecipient Monitoring Repeat Finding: Yes (Prior Year Finding No. 2023-008) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, UL Lafayette did not adequately monitor subrecipients of the Research and Development (R&D) Cluster Programs. In a non-statistical sample of seven subawards out of a population of 50 subawards, it was noted that for six (85.7%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the financial and performance reports required by the subaward agreement were obtained and reviewed by UL Lafayette. For three (42.9%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients’ fraud risk and risk of noncompliance with federal regulations and the terms of the subaward. For two of the subrecipients reviewed (28.6%), UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit and that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for one (14.3%) of the subrecipients evaluated, the subaward documents did not contain the federal award date as required by federal regulations. Criteria: Per 2 CFR 200.332(b)(1)(iv), all pass-through entities must ensure that every subaward includes the federal award date. 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient's fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. 2 CFR 200.332(e)(1) requires that pass-through monitoring include reviewing financial and performance reports required by the pass-through entity. 2 CFR 200.332(e)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings, in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient’s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings. Per 2 CFR 200.332(g), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient’s fiscal year. Cause: UL Lafayette did not have sufficient controls in place to adequately monitor subrecipients as required by federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency. Recommendation: UL Lafayette should strengthen controls to ensure that all required financial and performance reports are obtained and reviewed and that all required subrecipient audit reports are obtained and reviewed in order to evaluate the impact of any findings noted by the audit and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure that required information is included in the subaward documents and that risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-64).
2024-008 - Noncompliance with Subrecipient Monitoring Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2019 - 2023 Award Numbers: DE-EE0009421, FA9550-21-1-0215, M19AC00015, OIA-1920858, OIA-2019511, OIA-2119688, U19AI142636 Compliance Requirement: Subrecipient Monitoring Repeat Finding: Yes (Prior Year Finding No. 2023-008) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, UL Lafayette did not adequately monitor subrecipients of the Research and Development (R&D) Cluster Programs. In a non-statistical sample of seven subawards out of a population of 50 subawards, it was noted that for six (85.7%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the financial and performance reports required by the subaward agreement were obtained and reviewed by UL Lafayette. For three (42.9%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients’ fraud risk and risk of noncompliance with federal regulations and the terms of the subaward. For two of the subrecipients reviewed (28.6%), UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit and that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for one (14.3%) of the subrecipients evaluated, the subaward documents did not contain the federal award date as required by federal regulations. Criteria: Per 2 CFR 200.332(b)(1)(iv), all pass-through entities must ensure that every subaward includes the federal award date. 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient's fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. 2 CFR 200.332(e)(1) requires that pass-through monitoring include reviewing financial and performance reports required by the pass-through entity. 2 CFR 200.332(e)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings, in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient’s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings. Per 2 CFR 200.332(g), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient’s fiscal year. Cause: UL Lafayette did not have sufficient controls in place to adequately monitor subrecipients as required by federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency. Recommendation: UL Lafayette should strengthen controls to ensure that all required financial and performance reports are obtained and reviewed and that all required subrecipient audit reports are obtained and reviewed in order to evaluate the impact of any findings noted by the audit and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure that required information is included in the subaward documents and that risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-64).
2024-033 - Noncompliance with and Inadequate Controls over Subrecipient Monitoring Requirements at Pennington Biomedical Research Center State Entity: Louisiana State University and Related Campuses Award Years: 2021, 2022, 2023 Award Numbers: 1P50MD017338-01, 1R01DK132011-01A1, 1U01AG073204-01, 1U01CA271279-01 Compliance Requirement: Subrecipient Monitoring Pass-Through Entity: University of Alabama at Birmingham Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: The Pennington Biomedical Research Center (PBRC) did not adequately monitor subrecipients of the Research and Development (R&D) Cluster programs. In a non-statistical sample of nine grants to subrecipients, out of a population of 61 grants, it was noted that for five (56%) of the grants evaluated, PBRC could not provide evidence that the required risk analyses were performed to evaluate the subrecipient’s fraud risk and risk of noncompliance with the subaward agreement. Criteria: 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient’s fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. Cause: PBRC did not follow established controls to ensure that R&D Cluster award subrecipients were monitored in accordance with federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal grantor. Recommendation: PBRC should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-38).
2024-033 - Noncompliance with and Inadequate Controls over Subrecipient Monitoring Requirements at Pennington Biomedical Research Center State Entity: Louisiana State University and Related Campuses Award Years: 2021, 2022, 2023 Award Numbers: 1P50MD017338-01, 1R01DK132011-01A1, 1U01AG073204-01, 1U01CA271279-01 Compliance Requirement: Subrecipient Monitoring Pass-Through Entity: University of Alabama at Birmingham Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: The Pennington Biomedical Research Center (PBRC) did not adequately monitor subrecipients of the Research and Development (R&D) Cluster programs. In a non-statistical sample of nine grants to subrecipients, out of a population of 61 grants, it was noted that for five (56%) of the grants evaluated, PBRC could not provide evidence that the required risk analyses were performed to evaluate the subrecipient’s fraud risk and risk of noncompliance with the subaward agreement. Criteria: 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient’s fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. Cause: PBRC did not follow established controls to ensure that R&D Cluster award subrecipients were monitored in accordance with federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal grantor. Recommendation: PBRC should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-38).
2024-033 - Noncompliance with and Inadequate Controls over Subrecipient Monitoring Requirements at Pennington Biomedical Research Center State Entity: Louisiana State University and Related Campuses Award Years: 2021, 2022, 2023 Award Numbers: 1P50MD017338-01, 1R01DK132011-01A1, 1U01AG073204-01, 1U01CA271279-01 Compliance Requirement: Subrecipient Monitoring Pass-Through Entity: University of Alabama at Birmingham Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: The Pennington Biomedical Research Center (PBRC) did not adequately monitor subrecipients of the Research and Development (R&D) Cluster programs. In a non-statistical sample of nine grants to subrecipients, out of a population of 61 grants, it was noted that for five (56%) of the grants evaluated, PBRC could not provide evidence that the required risk analyses were performed to evaluate the subrecipient’s fraud risk and risk of noncompliance with the subaward agreement. Criteria: 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient’s fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. Cause: PBRC did not follow established controls to ensure that R&D Cluster award subrecipients were monitored in accordance with federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal grantor. Recommendation: PBRC should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-38).
2024-008 - Noncompliance with Subrecipient Monitoring Requirements State Entity: University of Louisiana at Lafayette (UL Lafayette) Award Years: 2019 - 2023 Award Numbers: DE-EE0009421, FA9550-21-1-0215, M19AC00015, OIA-1920858, OIA-2019511, OIA-2119688, U19AI142636 Compliance Requirement: Subrecipient Monitoring Repeat Finding: Yes (Prior Year Finding No. 2023-008) See Schedule of Findings and Questioned Costs for chart/table. Condition: For the fourth consecutive year, UL Lafayette did not adequately monitor subrecipients of the Research and Development (R&D) Cluster Programs. In a non-statistical sample of seven subawards out of a population of 50 subawards, it was noted that for six (85.7%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the financial and performance reports required by the subaward agreement were obtained and reviewed by UL Lafayette. For three (42.9%) of the subrecipients evaluated, UL Lafayette could not provide evidence that the required risk analyses were performed to evaluate each subrecipients’ fraud risk and risk of noncompliance with federal regulations and the terms of the subaward. For two of the subrecipients reviewed (28.6%), UL Lafayette was unable to provide documentation that ensured each subrecipient obtained the required audit and that the audit was reviewed so that timely and appropriate action could be taken for any findings pertaining to the federal awards, as required by federal regulations. Additionally, for one (14.3%) of the subrecipients evaluated, the subaward documents did not contain the federal award date as required by federal regulations. Criteria: Per 2 CFR 200.332(b)(1)(iv), all pass-through entities must ensure that every subaward includes the federal award date. 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient's fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. 2 CFR 200.332(e)(1) requires that pass-through monitoring include reviewing financial and performance reports required by the pass-through entity. 2 CFR 200.332(e)(2) and (3) require pass-through entities to issue a management decision on applicable audit findings, in accordance with 2 CFR 200.521, within six months after acceptance of the subrecipient’s audit report by the Federal Audit Clearinghouse, and ensure that the subrecipient takes timely and appropriate corrective action on all findings. Per 2 CFR 200.332(g), pass-through entities are responsible for verifying that every subrecipient is audited as required by 2 CFR Part 200, subpart F when it is expected that the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR 200.501 of $750,000 or more in federal awards during the subrecipient’s fiscal year. Cause: UL Lafayette did not have sufficient controls in place to adequately monitor subrecipients as required by federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal awarding agency. Recommendation: UL Lafayette should strengthen controls to ensure that all required financial and performance reports are obtained and reviewed and that all required subrecipient audit reports are obtained and reviewed in order to evaluate the impact of any findings noted by the audit and issue management decision letters, if applicable. In addition, UL Lafayette should strengthen controls to ensure that required information is included in the subaward documents and that risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-64).
2024-033 - Noncompliance with and Inadequate Controls over Subrecipient Monitoring Requirements at Pennington Biomedical Research Center State Entity: Louisiana State University and Related Campuses Award Years: 2021, 2022, 2023 Award Numbers: 1P50MD017338-01, 1R01DK132011-01A1, 1U01AG073204-01, 1U01CA271279-01 Compliance Requirement: Subrecipient Monitoring Pass-Through Entity: University of Alabama at Birmingham Repeat Finding: No See Schedule of Findings and Questioned Costs for chart/table. Condition: The Pennington Biomedical Research Center (PBRC) did not adequately monitor subrecipients of the Research and Development (R&D) Cluster programs. In a non-statistical sample of nine grants to subrecipients, out of a population of 61 grants, it was noted that for five (56%) of the grants evaluated, PBRC could not provide evidence that the required risk analyses were performed to evaluate the subrecipient’s fraud risk and risk of noncompliance with the subaward agreement. Criteria: 2 CFR 200.332(c) requires pass through entities to evaluate each subrecipient’s fraud risk and risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for the purpose of determining the appropriate subrecipient monitoring. Cause: PBRC did not follow established controls to ensure that R&D Cluster award subrecipients were monitored in accordance with federal regulations. Effect: Failure to properly monitor subrecipients results in noncompliance with federal regulations and increases the likelihood of improper payments which may have to be returned to the federal grantor. Recommendation: PBRC should strengthen controls to ensure risk assessments are performed and documented on all subrecipients in accordance with federal regulations. Management’s Response and Corrective Action Plan: Management concurred with the finding and provided a corrective action plan (B-38).
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.