Finding 2024-003 - Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.332(b), a pass-through entity should ensure that every subaward is clearly identified to the subrecipient as a subaward and that includes appropriate federal award identification. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted the County failed to provide a subrecipient agreement to two subrecipient entities that would have included appropriate information related to federal award identification. Cause: The County failed to review for a proper distribution of a subrecipient agreement to subrecipient entities that would have included appropriate information related to federal award identification. Effect: There is an increased risk that subrecipient noncompliance with federal requirements may go undetected. Recommendation:. We recommend that the County develop a subrecipient monitoring checklist that includes verifying that a subrecipient agreement was provided to the entity receiving an award.
Criteria: In accordance with 2 CFR §200.332(f), a 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. This includes verifying that subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of 2 CFR Part 200, Subpart F—Audit Requirements. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted that the County did not have a documented process in place to track and maintain copies of all Single Audit reports for subrecipients to whom it awarded federal funds. Specifically, the County was unable to provide evidence that it had verified with the pass-through entities that have received federal funds below $750,000 whether they were subject to a single audit, the County only followed the verification process for pass-through entities that received federal award in excess of $750,000. Cause: The County did not establish or implement formal procedures to track subrecipient audit status or to obtain and review Single Audit reports. Effect: Without a process to obtain and review Single Audit reports, the County cannot ensure that subrecipients are complying with federal requirements, which increases the risk of undetected noncompliance or misuse of federal funds. Recommendation:. We recommend that the County develop and implement formal procedures to identify subrecipients subject to the Single Audit requirements, obtain and review their audit reports annually, and follow up on any audit findings that may impact the County’s federal programs.
Finding 2024-003 - Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.332(b), a pass-through entity should ensure that every subaward is clearly identified to the subrecipient as a subaward and that includes appropriate federal award identification. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted the County failed to provide a subrecipient agreement to two subrecipient entities that would have included appropriate information related to federal award identification. Cause: The County failed to review for a proper distribution of a subrecipient agreement to subrecipient entities that would have included appropriate information related to federal award identification. Effect: There is an increased risk that subrecipient noncompliance with federal requirements may go undetected. Recommendation:. We recommend that the County develop a subrecipient monitoring checklist that includes verifying that a subrecipient agreement was provided to the entity receiving an award.
Criteria: In accordance with 2 CFR §200.332(f), a 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. This includes verifying that subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of 2 CFR Part 200, Subpart F—Audit Requirements. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted that the County did not have a documented process in place to track and maintain copies of all Single Audit reports for subrecipients to whom it awarded federal funds. Specifically, the County was unable to provide evidence that it had verified with the pass-through entities that have received federal funds below $750,000 whether they were subject to a single audit, the County only followed the verification process for pass-through entities that received federal award in excess of $750,000. Cause: The County did not establish or implement formal procedures to track subrecipient audit status or to obtain and review Single Audit reports. Effect: Without a process to obtain and review Single Audit reports, the County cannot ensure that subrecipients are complying with federal requirements, which increases the risk of undetected noncompliance or misuse of federal funds. Recommendation:. We recommend that the County develop and implement formal procedures to identify subrecipients subject to the Single Audit requirements, obtain and review their audit reports annually, and follow up on any audit findings that may impact the County’s federal programs.
Subrecipient Monitoring Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 002 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, “the recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Section 200.332. Requirements for pass-through entities, requires that “A pass-through entity must: (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency)... (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In 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 notifications 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 a management decision for audit findings pertaining 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…. (g)Verify that a subrecipient is audited as required by subpart F of this part. (h) Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations. CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its subrecipient monitoring requirements as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding was an inadequate understanding of sub-recipient monitoring policies and best practices. While the Department believed at the time that they were in compliance with the applicable monitoring requirements, they now recognize that their efforts did not fully meet the necessary standards. EFFECT Failure to adequately perform and document the risk assessments on its subrecipient(s) could result in the inadequate monitoring of the activities and performance of a subrecipient. Also, this could result in Federal awards being used by the subrecipient for unauthorized purposes. QUESTIONED COSTS None. CONTEXT During our review of two (2) subrecipients (of a population of 4 subrecipients), we noted the following: For both subrecipients, we noted documentation was not maintained to support SAO’s evaluation of the subrecipients’ risk of noncompliance and the frequency of monitoring to be conducted by SAO based on the assessed risk. We also noted for both subrecipients, no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including SAO’s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332e(3). The SAO utilized a “Subrecipient Monitoring Checklist” (Checklist) to conduct and document its monitoring of subrecipients. Based on review, we noted the Checklist does not include evidence of who completed the monitoring, the date the actual monitoring was performed nor the subrecipient personnel with whom the monitoring results were discussed during the site visit. Also, the Checklist appears to be inaccurately completed. Specifically, we noted the Checklist noted that the results include expected corrective actions and dates for resolution. However, there was no finding or issues noted in the formal letter submitted to the subrecipient(s) after the site visit(s). IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend SAO implement procedures to ensure adequate documentation is maintained to support the evaluation of each subrecipient’s risk of noncompliance and review of the Single audit report, as required by Federal regulations. Also, we suggest that the Checklist be accurately prepared and updated to include evidence of who completed the monitoring, the date the actual monitoring was performed, and the subrecipient personnel with whom the monitoring results were discussed during the site visit. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on pages 38-39.
Reporting Federal Department – U.S. Department of Treasury Pass-through Illinois Department of Human Services Federal Award Identification Number and Year: SLFRP4406 and 2021 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, Federal Assistance Listing #21.027 County Department – Justice Advisory Council Finding 2024 – 003 CRITERIA As required by the grant agreement with the State of Illinois, Department of Human Services (IDHS), Exhibit B, Deliverables. 4. Reporting Requirements, states “i. Pursuant to Paragraph 13.1 and 13.2 Cook County will submit monthly, quarterly and final Periodic Financial Reports (PFRs) in the format prescribed by IDHS. The monthly, quarterly and final Periodic Financial Reports must be submitted no later than the 15th of each month for the preceding month or quarter by email. The final year-end report (July 1st - June 30th) will be due on or before July 15th or no more than 30 days following grant termination. ii. Pursuant to Paragraph 13.1 and 13.2 Cook County will submit quarterly and final Periodic Performance Reports (PPRs) in the format prescribed by IDHS. Quarterly and Final Periodic Performance Reports are due no later than the 15th of each month for the preceding quarter by email. Quarter 1 (July 1st - September 30th) due October 15th, Quarter 2 (October 1st- December 31st) due January 15th, Quarter 3 (January 1st- March 31st) due April 15th, and Quarter 4 (April 1st- June 30th) due July 15th). The final year-end report (July 1st -June 30th) will be due on or before July 15th or no more than 30 days following grant termination. Performance reports will include a detailed account of how Cook County is ensuring compliance with 2 CFR 200.332. iii. Annual Program Application Plan: Providers are required to submit an Annual Program Application/Plan each year. Annual Program Plans for Programs exempt from 30 ILCS 708 (GATA) or during a renewal year will be due in April/May of each year for the upcoming program year.” CONDITION During the current audit period, Cook County Justice Advisory Council (JAC) did not comply with the reporting requirements as outlined in its grant agreement. CAUSE Based on discussions with management, the March 2024 monthly financial finding occurred due to reconciling actual expenditures for the 5-month grant period close-out. The quarterly performance report finding occurred due to an adjusted 30 days reporting schedule allowed verbally by the grantor. EFFECT Failure to submit reports in a timely manner could impair the grantor agency’s ability to monitor program activities and could result in the loss of grant funding. QUESTIONED COSTS None. CONTEXT During our review, we noted the IDHS grant agreement ended on June 30, 2024, which represented seven months of required reporting to be submitted during the County’s fiscal year. As a result, we reviewed a total of eight reports submitted (three monthly financial (of a population of 7 monthly reports), one quarterly financial and one quarterly performance report (of a population of 2 quarterly financial and performance reports), one final financial and one final performance report, and one annual program application plan report), and noted 2 of the eight reports reviewed were submitted late. See Finding for Chart/ Table. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend JAC develop and implement procedures to ensure reports are submitted in a timely manner and in compliance with its grant agreement. A compliance calendar of all future grants reporting due dates should be maintained to assist with ensuring future compliance with reporting requirements. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on pages 40-41.
Finding 2024-003 - Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.332(b), a pass-through entity should ensure that every subaward is clearly identified to the subrecipient as a subaward and that includes appropriate federal award identification. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted the County failed to provide a subrecipient agreement to two subrecipient entities that would have included appropriate information related to federal award identification. Cause: The County failed to review for a proper distribution of a subrecipient agreement to subrecipient entities that would have included appropriate information related to federal award identification. Effect: There is an increased risk that subrecipient noncompliance with federal requirements may go undetected. Recommendation:. We recommend that the County develop a subrecipient monitoring checklist that includes verifying that a subrecipient agreement was provided to the entity receiving an award.
Criteria: In accordance with 2 CFR §200.332(f), a 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. This includes verifying that subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of 2 CFR Part 200, Subpart F—Audit Requirements. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted that the County did not have a documented process in place to track and maintain copies of all Single Audit reports for subrecipients to whom it awarded federal funds. Specifically, the County was unable to provide evidence that it had verified with the pass-through entities that have received federal funds below $750,000 whether they were subject to a single audit, the County only followed the verification process for pass-through entities that received federal award in excess of $750,000. Cause: The County did not establish or implement formal procedures to track subrecipient audit status or to obtain and review Single Audit reports. Effect: Without a process to obtain and review Single Audit reports, the County cannot ensure that subrecipients are complying with federal requirements, which increases the risk of undetected noncompliance or misuse of federal funds. Recommendation:. We recommend that the County develop and implement formal procedures to identify subrecipients subject to the Single Audit requirements, obtain and review their audit reports annually, and follow up on any audit findings that may impact the County’s federal programs.
Finding 2024-003 - Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.332(b), a pass-through entity should ensure that every subaward is clearly identified to the subrecipient as a subaward and that includes appropriate federal award identification. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted the County failed to provide a subrecipient agreement to two subrecipient entities that would have included appropriate information related to federal award identification. Cause: The County failed to review for a proper distribution of a subrecipient agreement to subrecipient entities that would have included appropriate information related to federal award identification. Effect: There is an increased risk that subrecipient noncompliance with federal requirements may go undetected. Recommendation:. We recommend that the County develop a subrecipient monitoring checklist that includes verifying that a subrecipient agreement was provided to the entity receiving an award.
Criteria: In accordance with 2 CFR §200.332(f), a 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. This includes verifying that subrecipients expending $750,000 or more in federal awards during the subrecipient’s fiscal year have met the audit requirements of 2 CFR Part 200, Subpart F—Audit Requirements. Condition: During our audit of the County’s administration of federal funds under the CSLFRF program, we noted that the County did not have a documented process in place to track and maintain copies of all Single Audit reports for subrecipients to whom it awarded federal funds. Specifically, the County was unable to provide evidence that it had verified with the pass-through entities that have received federal funds below $750,000 whether they were subject to a single audit, the County only followed the verification process for pass-through entities that received federal award in excess of $750,000. Cause: The County did not establish or implement formal procedures to track subrecipient audit status or to obtain and review Single Audit reports. Effect: Without a process to obtain and review Single Audit reports, the County cannot ensure that subrecipients are complying with federal requirements, which increases the risk of undetected noncompliance or misuse of federal funds. Recommendation:. We recommend that the County develop and implement formal procedures to identify subrecipients subject to the Single Audit requirements, obtain and review their audit reports annually, and follow up on any audit findings that may impact the County’s federal programs.
Finding 2024-012 – Subrecipient Monitoring (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG). Criteria: 2 CFR 200.332 establishes subrecipient monitoring requirements of all pass through entities. These requirements include that every subaward is clearly identified to the subrecipient as a subaward and includes the following information: assistance listings title and number, the dollar amount made available under each federal award, and the assistance listings number at the time of disbursement, etc. These requirements also include evaluating each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Evaluations of a subrecipient's risk should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any federal agency monitoring. In addition, subrecipient activities must be monitored to ensure compliance with federal statutes, regulations, and terms and conditions of the subaward. Monitoring must include the review of financial and performance reports, ensure that corrective action is taken by the subrecipient on any significant developments impacting the subaward, and resolving findings specifically related to the subaward. The City has a grants manual in place that includes requirements of subrecipient and contract oversight. The policy includes processes to perform pre-award evaluations, post-award monitoring and closeout reporting to ensure compliance. Condition: Minority Health – two subawards were tested for monitoring requirements. One of the subaward agreements did not include a required piece of information in the award document. CDBG - two subawards were tested for monitoring requirements. Pre-risk assessment procedures were not documented as performed prior to the subaward date on either subrecipient. In addition, one subrecipient had deficiencies noted in their annual audit. The City did not perform required monitoring duties to ensure the subrecipient took timely and appropriate action on the deficiencies reported. Cause: Minority Health - the City did not communicate the federal assistance listing number in the subaward document. CDBG - did not document a pre-award risk assessment or follow up of corrective action for reported audit findings for their subrecipients. Effect: The City did not have proper subrecipient monitoring documentation. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with federal subrecipient monitoring requirements and its policies and procedures to perform all subrecipient oversight responsibilities to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-012 – Subrecipient Monitoring (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG). Criteria: 2 CFR 200.332 establishes subrecipient monitoring requirements of all pass through entities. These requirements include that every subaward is clearly identified to the subrecipient as a subaward and includes the following information: assistance listings title and number, the dollar amount made available under each federal award, and the assistance listings number at the time of disbursement, etc. These requirements also include evaluating each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Evaluations of a subrecipient's risk should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any federal agency monitoring. In addition, subrecipient activities must be monitored to ensure compliance with federal statutes, regulations, and terms and conditions of the subaward. Monitoring must include the review of financial and performance reports, ensure that corrective action is taken by the subrecipient on any significant developments impacting the subaward, and resolving findings specifically related to the subaward. The City has a grants manual in place that includes requirements of subrecipient and contract oversight. The policy includes processes to perform pre-award evaluations, post-award monitoring and closeout reporting to ensure compliance. Condition: Minority Health – two subawards were tested for monitoring requirements. One of the subaward agreements did not include a required piece of information in the award document. CDBG - two subawards were tested for monitoring requirements. Pre-risk assessment procedures were not documented as performed prior to the subaward date on either subrecipient. In addition, one subrecipient had deficiencies noted in their annual audit. The City did not perform required monitoring duties to ensure the subrecipient took timely and appropriate action on the deficiencies reported. Cause: Minority Health - the City did not communicate the federal assistance listing number in the subaward document. CDBG - did not document a pre-award risk assessment or follow up of corrective action for reported audit findings for their subrecipients. Effect: The City did not have proper subrecipient monitoring documentation. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with federal subrecipient monitoring requirements and its policies and procedures to perform all subrecipient oversight responsibilities to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-012 – Subrecipient Monitoring (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG). Criteria: 2 CFR 200.332 establishes subrecipient monitoring requirements of all pass through entities. These requirements include that every subaward is clearly identified to the subrecipient as a subaward and includes the following information: assistance listings title and number, the dollar amount made available under each federal award, and the assistance listings number at the time of disbursement, etc. These requirements also include evaluating each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Evaluations of a subrecipient's risk should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any federal agency monitoring. In addition, subrecipient activities must be monitored to ensure compliance with federal statutes, regulations, and terms and conditions of the subaward. Monitoring must include the review of financial and performance reports, ensure that corrective action is taken by the subrecipient on any significant developments impacting the subaward, and resolving findings specifically related to the subaward. The City has a grants manual in place that includes requirements of subrecipient and contract oversight. The policy includes processes to perform pre-award evaluations, post-award monitoring and closeout reporting to ensure compliance. Condition: Minority Health – two subawards were tested for monitoring requirements. One of the subaward agreements did not include a required piece of information in the award document. CDBG - two subawards were tested for monitoring requirements. Pre-risk assessment procedures were not documented as performed prior to the subaward date on either subrecipient. In addition, one subrecipient had deficiencies noted in their annual audit. The City did not perform required monitoring duties to ensure the subrecipient took timely and appropriate action on the deficiencies reported. Cause: Minority Health - the City did not communicate the federal assistance listing number in the subaward document. CDBG - did not document a pre-award risk assessment or follow up of corrective action for reported audit findings for their subrecipients. Effect: The City did not have proper subrecipient monitoring documentation. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with federal subrecipient monitoring requirements and its policies and procedures to perform all subrecipient oversight responsibilities to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-012 – Subrecipient Monitoring (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG). Criteria: 2 CFR 200.332 establishes subrecipient monitoring requirements of all pass through entities. These requirements include that every subaward is clearly identified to the subrecipient as a subaward and includes the following information: assistance listings title and number, the dollar amount made available under each federal award, and the assistance listings number at the time of disbursement, etc. These requirements also include evaluating each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Evaluations of a subrecipient's risk should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any federal agency monitoring. In addition, subrecipient activities must be monitored to ensure compliance with federal statutes, regulations, and terms and conditions of the subaward. Monitoring must include the review of financial and performance reports, ensure that corrective action is taken by the subrecipient on any significant developments impacting the subaward, and resolving findings specifically related to the subaward. The City has a grants manual in place that includes requirements of subrecipient and contract oversight. The policy includes processes to perform pre-award evaluations, post-award monitoring and closeout reporting to ensure compliance. Condition: Minority Health – two subawards were tested for monitoring requirements. One of the subaward agreements did not include a required piece of information in the award document. CDBG - two subawards were tested for monitoring requirements. Pre-risk assessment procedures were not documented as performed prior to the subaward date on either subrecipient. In addition, one subrecipient had deficiencies noted in their annual audit. The City did not perform required monitoring duties to ensure the subrecipient took timely and appropriate action on the deficiencies reported. Cause: Minority Health - the City did not communicate the federal assistance listing number in the subaward document. CDBG - did not document a pre-award risk assessment or follow up of corrective action for reported audit findings for their subrecipients. Effect: The City did not have proper subrecipient monitoring documentation. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with federal subrecipient monitoring requirements and its policies and procedures to perform all subrecipient oversight responsibilities to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-012 – Subrecipient Monitoring (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG). Criteria: 2 CFR 200.332 establishes subrecipient monitoring requirements of all pass through entities. These requirements include that every subaward is clearly identified to the subrecipient as a subaward and includes the following information: assistance listings title and number, the dollar amount made available under each federal award, and the assistance listings number at the time of disbursement, etc. These requirements also include evaluating each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Evaluations of a subrecipient's risk should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any federal agency monitoring. In addition, subrecipient activities must be monitored to ensure compliance with federal statutes, regulations, and terms and conditions of the subaward. Monitoring must include the review of financial and performance reports, ensure that corrective action is taken by the subrecipient on any significant developments impacting the subaward, and resolving findings specifically related to the subaward. The City has a grants manual in place that includes requirements of subrecipient and contract oversight. The policy includes processes to perform pre-award evaluations, post-award monitoring and closeout reporting to ensure compliance. Condition: Minority Health – two subawards were tested for monitoring requirements. One of the subaward agreements did not include a required piece of information in the award document. CDBG - two subawards were tested for monitoring requirements. Pre-risk assessment procedures were not documented as performed prior to the subaward date on either subrecipient. In addition, one subrecipient had deficiencies noted in their annual audit. The City did not perform required monitoring duties to ensure the subrecipient took timely and appropriate action on the deficiencies reported. Cause: Minority Health - the City did not communicate the federal assistance listing number in the subaward document. CDBG - did not document a pre-award risk assessment or follow up of corrective action for reported audit findings for their subrecipients. Effect: The City did not have proper subrecipient monitoring documentation. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with federal subrecipient monitoring requirements and its policies and procedures to perform all subrecipient oversight responsibilities to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
Finding 2024-012 – Subrecipient Monitoring (Significant Deficiency and Noncompliance) Identification of the Federal Program: Community Program to Improve Minority Health, ALN 93.137, Department of Health and Human Services (Minority Health); Community Development Block Grants, ALN 14.218, Department of Housing and Urban Development (CDBG). Criteria: 2 CFR 200.332 establishes subrecipient monitoring requirements of all pass through entities. These requirements include that every subaward is clearly identified to the subrecipient as a subaward and includes the following information: assistance listings title and number, the dollar amount made available under each federal award, and the assistance listings number at the time of disbursement, etc. These requirements also include evaluating each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. Evaluations of a subrecipient's risk should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of any federal agency monitoring. In addition, subrecipient activities must be monitored to ensure compliance with federal statutes, regulations, and terms and conditions of the subaward. Monitoring must include the review of financial and performance reports, ensure that corrective action is taken by the subrecipient on any significant developments impacting the subaward, and resolving findings specifically related to the subaward. The City has a grants manual in place that includes requirements of subrecipient and contract oversight. The policy includes processes to perform pre-award evaluations, post-award monitoring and closeout reporting to ensure compliance. Condition: Minority Health – two subawards were tested for monitoring requirements. One of the subaward agreements did not include a required piece of information in the award document. CDBG - two subawards were tested for monitoring requirements. Pre-risk assessment procedures were not documented as performed prior to the subaward date on either subrecipient. In addition, one subrecipient had deficiencies noted in their annual audit. The City did not perform required monitoring duties to ensure the subrecipient took timely and appropriate action on the deficiencies reported. Cause: Minority Health - the City did not communicate the federal assistance listing number in the subaward document. CDBG - did not document a pre-award risk assessment or follow up of corrective action for reported audit findings for their subrecipients. Effect: The City did not have proper subrecipient monitoring documentation. Questioned Costs: None reported. Recommendation: We recommend the City should strengthen procedures to ensure it complies with federal subrecipient monitoring requirements and its policies and procedures to perform all subrecipient oversight responsibilities to ensure compliance with federal subrecipient monitoring requirements. Views of Responsible Officials: The City agrees with the finding. See Management’s View and Corrective Action Plan included at the end of the report.
2024-001 – Communication with Subrecipients Finding Type: Significant Deficiency in internal control over compliance / noncompliance Program: ALN 93.958 – Inter-Connections Drop-In Integrated Health Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Contract selected for testing was not in compliance with 2 CFR 200.332. Questioned Cost: None. Recommendation: We recommend that the CMHSP update all contracts with subrecipients to include required language. View of Responsible Official: Management is in agreement with this recommendation.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
SD 2024‐003 SUBRECIPIENT MONITORING United States Environmental Protection Agency ALN 66.456 – National Estuary Program Federal Award ID Number: CE‐00D90119, 4T‐02D39922, CE‐02D56923 2024 Funding Repeat finding Criteria: 2 CFR 200.303 requires non‐federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes all requirements imposed by the pass‐through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass‐through entity imposes on the subrecipient in order for the pass‐through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: The Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: The Council requested audits from it's subrecipients; however, if the most recent year was not yet available the prior fiscal year's audit was not requested to review for any deficiencies. Effect: Without the monitoring of the results of audits and on‐site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. For the 8 subrecipients sampled, audit reports were obtained for 4 subrecipients. Recommendation: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring.
2024-002 – Subrecipient Monitoring - Lack of evidence of subrecipient Uniform Guidance report reviews Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Enabling Low Temperature Plasma (LTP) Ignition Technologies for Multi- Mode Engines Through the Development of a Validated High Fidelity LTP Model for Predictive Simulation Tools, Greater Alabama Black Belt Region (GABBR) LSAMP, and Reimagining controlled environment agriculture in a low carbon world Award Numbers: 211809, 200634, and 205280 Assistance Listing Title: Conservation Research and Development, STEM Education (formerly Education and Human Resources), and Agriculture and Food Research Initiative (AFRI) Assistance Listing Number: 81.086, 47.076, and 10.310 Award Year: 2023 - 2024 Pass-through entity: University of Texas Dallas, Association of Public & Land Grant Universities, Tuskegee University, and Clemson University Criteria 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition Through our testing of 25 subrecipients, we noted the following: • For the Research and Development Cluster, 3 out of 25 samples tested did not have supporting documentation to verify Auburn’s review of subrecipient’s financial statements and/or Uniform Guidance report available. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR 200.501. Additionally, due to a lack of clearly defined roles, responsibilities, and documentation practices among the existing team members within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The inconsistency of reviews performed over subrecipient financial statements and Uniform Guidance reports may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated, and other applicable procedures not being performed timely and appropriately. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around the review process of subrecipient financial statements and Uniform Guidance reports. The University should ensure its procedures properly address the review process of this information, including timeliness and appropriate personnel. The University should also ensure these annual reviews are being appropriately documented and the documentation is being maintained properly. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2024-002 – Subrecipient Monitoring - Lack of evidence of subrecipient Uniform Guidance report reviews Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Enabling Low Temperature Plasma (LTP) Ignition Technologies for Multi- Mode Engines Through the Development of a Validated High Fidelity LTP Model for Predictive Simulation Tools, Greater Alabama Black Belt Region (GABBR) LSAMP, and Reimagining controlled environment agriculture in a low carbon world Award Numbers: 211809, 200634, and 205280 Assistance Listing Title: Conservation Research and Development, STEM Education (formerly Education and Human Resources), and Agriculture and Food Research Initiative (AFRI) Assistance Listing Number: 81.086, 47.076, and 10.310 Award Year: 2023 - 2024 Pass-through entity: University of Texas Dallas, Association of Public & Land Grant Universities, Tuskegee University, and Clemson University Criteria 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition Through our testing of 25 subrecipients, we noted the following: • For the Research and Development Cluster, 3 out of 25 samples tested did not have supporting documentation to verify Auburn’s review of subrecipient’s financial statements and/or Uniform Guidance report available. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR 200.501. Additionally, due to a lack of clearly defined roles, responsibilities, and documentation practices among the existing team members within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The inconsistency of reviews performed over subrecipient financial statements and Uniform Guidance reports may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated, and other applicable procedures not being performed timely and appropriately. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around the review process of subrecipient financial statements and Uniform Guidance reports. The University should ensure its procedures properly address the review process of this information, including timeliness and appropriate personnel. The University should also ensure these annual reviews are being appropriately documented and the documentation is being maintained properly. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2024-002 – Subrecipient Monitoring - Lack of evidence of subrecipient Uniform Guidance report reviews Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Enabling Low Temperature Plasma (LTP) Ignition Technologies for Multi- Mode Engines Through the Development of a Validated High Fidelity LTP Model for Predictive Simulation Tools, Greater Alabama Black Belt Region (GABBR) LSAMP, and Reimagining controlled environment agriculture in a low carbon world Award Numbers: 211809, 200634, and 205280 Assistance Listing Title: Conservation Research and Development, STEM Education (formerly Education and Human Resources), and Agriculture and Food Research Initiative (AFRI) Assistance Listing Number: 81.086, 47.076, and 10.310 Award Year: 2023 - 2024 Pass-through entity: University of Texas Dallas, Association of Public & Land Grant Universities, Tuskegee University, and Clemson University Criteria 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition Through our testing of 25 subrecipients, we noted the following: • For the Research and Development Cluster, 3 out of 25 samples tested did not have supporting documentation to verify Auburn’s review of subrecipient’s financial statements and/or Uniform Guidance report available. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR 200.501. Additionally, due to a lack of clearly defined roles, responsibilities, and documentation practices among the existing team members within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The inconsistency of reviews performed over subrecipient financial statements and Uniform Guidance reports may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated, and other applicable procedures not being performed timely and appropriately. Questioned Costs None noted. Recommendation We recommend that the University reassess the design of its controls around the review process of subrecipient financial statements and Uniform Guidance reports. The University should ensure its procedures properly address the review process of this information, including timeliness and appropriate personnel. The University should also ensure these annual reviews are being appropriately documented and the documentation is being maintained properly. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
Finding 2024-002: Subrecipient Monitoring Federal Program: Adv HIV & AIDS Epidemic Control (AHEC) Activity - ALN 98.U01 Criteria: Recipients of federal funding who pass-through federal funds to subrecipients must evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring (2 CFR 200.332 (e)). In monitoring a subrecipient, a pass-through entity must review financial and performance reports (2 CFR 200.332 (e)). A pass-through must consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. (2 CFR 200.332 (h)). Condition: Insufficient monitoring was performed over fixed amount subawards. Cause: Improper controls over subrecipient monitoring compliance requirement. Effect: Controls in place did not allow for sufficient monitoring over subrecipients. Questioned costs: None Context: Fixed amount subawards did not have documented subrecipient monitoring plans based on subrecipient’s risk assessment evaluations. Monitoring of fixed amount subawards was limited to reviewing milestone certification forms against milestone tables included in the subrecipient agreements. Financial audits or reports were not requested for non-U.S. based subrecipients as part of monitoring procedures. Repeat finding: No Recommendation: We recommend that management review subrecipient monitoring policies and procedures required over fixed amount subawards to ensure there are documented subrecipient monitoring plans based on the subrecipient’s assessed level of risk and to ensure that financial reports or audits of the subrecipients are requested for non-U.S. based subrecipients. Views of responsible officials: Management agrees with the finding. See corrective action plan.
FINDING 2024-027 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Subrecipient Monitoring - Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition MDOT, LEO, and the Michigan Strategic Fund (MSF) did not report to their subrecipients all subaward information as required by the Uniform Guidance. We noted: a. MDOT did not report for all 3 sampled CSLFRF subrecipients the following: UEI, FAIN, federal award date, subaward period of performance start and end date, subaward budget period start and end date, federal awarding agency name, ALN title, identification of whether the award is for research and development (R&D), indirect cost rate for the federal award, an approved federally recognized indirect cost rate for the subrecipient, and the closeout terms and conditions. b. LEO did not report the correct FAIN for 1 of 3 sampled CSLFRF subrecipients. c. MSF did not report one or more of the following for the 2 sampled CSLFRF subrecipients: identification of whether the award is for R&D, indirect cost rate for the federal award, and an approved federally recognized indirect cost rate for the subrecipient. Criteria Federal regulation 2 CFR 200.332(a) requires all pass-through entities ensure every subaward includes certain information. Cause For part a., MDOT informed us because of an oversight in the process of developing its subawards, it did not provide all required subaward information to subrecipients. MDOT believed it used the best available information at the time it developed and executed the subawards but later discovered the oversight. For part b., LEO informed us because of an oversight, it did not use the correct FAIN when creating the grant agreement. For part c., MSF's internal control was not sufficient to ensure it provided all required subaward information to subrecipients. Effect Subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with the federal requirements. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MDOT, LEO, and MSF report to their subrecipients all subaward information as required by the Uniform Guidance. Management Views MDOT, LEO, and MSF agree with the finding.
FINDING 2024-028 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition LEO, MSF, and EGLE did not properly monitor their subrecipients to ensure they complied with the Uniform Guidance. We noted: a. LEO and MSF did not have a process to identify or document if their subrecipients required a single audit. Therefore, LEO and MSF did not monitor these subrecipients to ensure the status or submission of their single audit reports and did not determine whether a management decision letter was needed. b. EGLE did not identify or document if its subrecipients required a single audit for 8 (67%) of 12 sampled subrecipients. We reviewed the federal audit clearinghouse (FAC) and noted 2 of the 8 subrecipients had single audit reports submitted to the FAC in fiscal year 2024. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521(d) requires the pass-through entity to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause For part a., LEO indicated because of limited staff resources it did not have a process in place to monitor subrecipient single audits. MSF indicated it believes its current process was sufficient because it requires the subrecipients to notify MSF upon completion of their single audits. For part b., EGLE informed us due to an increase in subrecipients and division of responsibilities, not all CSLFRF subrecipients were tracked for single audits. Effect LEO, MSF, and EGLE limited the State's assurance their subrecipients complied with grant requirements and implemented corrective actions for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to their records. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend LEO, MSF, and EGLE properly monitor their subrecipients to ensure they comply with the Uniform Guidance. Management Views For part a., LEO agrees with the finding. All three of MSF's subrecipient awards for the fiscal year were sampled totaling approximately $274,000 (0.3 percent of the total award). While MSF agrees with the finding that it did not have a written process to verify single audit compliance, management believes that MSF's risk assessment of subrecipients adequately determined that single audit verification was not required for two of its subrecipients since, based on all anticipated federal awards for the subrecipient, it was not expected that they would reach the expenditure threshold (2 CFR 200.332(f)). The third annually files a single audit, was expected to file a single audit, and did file a single audit. For part b., EGLE agrees with the finding. Auditor's Comments to Management Views Regarding part a., MSF acknowledges it does not have a process to identify or document its review of subrecipient single audit reports. MSF did not provide documentation to support the award period or the amount of the subaward to these three subrecipients. Regardless of the amount of the subaward, federal regulation 2 CFR 200.501 indicates the $750,000 threshold is based on the subrecipient's total federal expenditures for all federal programs during its fiscal year and not based on a specific program's subaward amounts or expenditures. Also, MSF did not review the single audit report submitted to the FAC and determine if it was necessary to issue a management decision letter for audit findings affecting the subawards it issued to the subrecipient. Therefore, the finding stands as written.
FINDING 2024-029 Adult Education - Basic Grants to States, ALN 84.002, Subrecipient Monitoring - During-the-Award Monitoring and Subaward Information See Schedule of Findings and Questioned Costs for chart/table. Condition LEO did not complete sufficient during-the-award monitoring of its subrecipients to ensure it complied with the Uniform Guidance. In addition, LEO did not accurately report to its subrecipients all subaward information as required by the Uniform Guidance. We noted: a. LEO did not fully complete desk audits for all 92 subrecipients. Therefore, LEO did not review and monitor these subrecipients to ensure their compliance with program requirements. b. LEO did not report the correct FAIN for all 92 subrecipients. Criteria Federal regulation 2 CFR 200.332(d) requires LEO to monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and that subaward performance goals are achieved. As part of its monitoring procedures, LEO completes an annual four-step desk audit of its subrecipients which includes review and approval of the subrecipient application narrative, budget, final expenditure report, and final narrative. Federal regulation 2 CFR 200.332(a) requires all pass-through entities ensure every subaward includes certain information. Cause For part a., LEO informed us competing priorities impacted its ability to complete the final two steps of the desk audits. For part b., LEO indicated the incorrect FAIN on the subrecipient subawards was caused by a manual data entry error. Effect Insufficient monitoring of subrecipients could increase the subrecipients' and LEO's noncompliance with federal statutes, regulations, or the terms and conditions of federal awards. Also, subrecipients and their auditors may not be aware of the federal award information needed to ensure compliance with federal requirements. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendations We recommend LEO complete sufficient during-the-award monitoring of its subrecipients to ensure they comply with the Uniform Guidance. We also recommend LEO accurately report to its subrecipients all subaward information as required by the Uniform Guidance. Management Views LEO agrees with the finding.
FINDING 2024-031 Twenty-First Century Community Learning Centers, ALN 84.287, Subrecipient Monitoring - Program Fiscal Reviews See Schedule of Findings and Questioned Costs for chart/table. Condition MiLEAP did not sufficiently monitor the activities of its subrecipients to ensure federal awards are used for authorized purposes. We noted MiLEAP did not complete program fiscal reviews for all 26 subrecipients. Criteria Federal regulation 2 CFR 200.332(d) requires MiLEAP to monitor the activities of the subrecipient as necessary to ensure the subaward is used for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward and the subaward performance goals are achieved. As part of its monitoring procedures, MiLEAP conducts an annual program fiscal review of each subrecipient. Cause MiLEAP informed us limited resources contributed to its inability to sufficiently monitor its subrecipients. Effect Insufficient monitoring of subrecipients could increase the subrecipients' and MiLEAP's, noncompliance with federal statutes, regulations, or the terms and conditions of federal awards. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend MiLEAP sufficiently monitor the activities of its subrecipients to ensure federal awards are used for authorized purposes. Management Views MiLEAP agrees with the finding.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.
Federal Agency: United States Department of Health and Human Services (HHS) Program Name: Research and Development Cluster ALN Number: Various Federal Award Year: July 1, 2023 – June 30, 2024 Criteria In accordance with 2 CFR 200.332, a pass through entity (PTE) must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and included the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (xii) Assistance Listing number (ALN) and Title; the pass through entity must identify the dollar amount made available under each Federal award and the ALN at time of disbursement (2 CFR section 200.332xxi) b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: The subrecipient’s prior experience with the same or similar subawards; (1) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (2) Whether the subrecipient has new personnel or new substantially changed systems; and (3) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Additionally, 45 CRF 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 When subawards are made to subrecipients, the pass through entities are required to communicate the dollar amount made available under each Federal award and the Assistance Listings Number (ALN) at time of disbursement. The Health System does not have system in place to provide the ALN at the time of disbursement of funds. During the year ended September 30, 2024, the Health System passed through $15,600,763 of federal funding to subrecipients. In order to assess the subrecipient’s risk of non compliance, The Health System has subrecipient monitoring policies and procedures in place which include the use of a risk assessment questionnaire. The risk assessment questionnaire includes considerations consistent with 2 CFR 200.332(b), including the entity’s prior experience and results of Uniform Guidance Audits, in addition to other factors. As part of our testing related subrecipient monitoring, we identified that for each of the 10 subrecipients selected for testwork, the Health System did not perform a risk assessment of the entity for purposes of determining the appropriate subrecipient monitoring related to the subaward. However, for these subrecipients, The Health System did perform monitoring procedures, including review of invoices for reimbursement, review of Research Performance Progress Reports, and review of Uniform Guidance Audit reports. Cause The condition found was primarily due to the monitoring procedures implemented by the Health System do not include a review to ensure that a risk assessment is performed for each active subrecipient, and the Health System does not have a mechanism in place to provide the ALN at the time of disbursement of funds to the subrecipient. The Health System has put efforts into the design and implement a risk assessment control process which commenced late in fiscal year 2024 and the ongoing efforts were not complete as of September 30, 2024. Possible Asserted Effect Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Questioned Costs None. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes. Recommendation We recommend management continue to fully implement the designed policies, procedures, and internal controls to ensure subrecipient risk assessments are performed for each subrecipient to determine the appropriate subrecipient monitoring is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Views of Responsible Officials Recommendation accepted. Please refer to corrective action plan.