Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
Finding 2024-002: Untimely Review of Subrecipient Single Audit Reports Federal Agency: The Corporation for National and Community Service U.S. Department of Agriculture (USDA) U.S. Department of Commerce (USDOC) U.S. Department of Defense (USDOD) U.S. Department of Education (USDE) U.S. Department of Energy (USDOE) U.S. Department of Health and Human Services (USDHHS) U.S. Department of Homeland Security (USDHS) U.S. Department of Housing and Urban Development (USHUD) U.S. Department of Interior (USDOI) U.S. Department of Justice (USDOJ) U.S. Department of Transportation (USDOT) U.S. Director of National Intelligence (USDNI) U.S. Environmental Protection Agency (USEPA) National Aeronautics and Space Administration (NASA) National Endowment for the Humanities (NEH) National Science Foundation (NSF) Social Security Administration (SSA) U.S. Department of Veteran Affairs (USDVA) All Pass-Through Entities Program Name: Research and Development (R&D) Cluster ALN and Program Expenditures: Various ($539,302,615) Federal Award Numbers: Various – See schedule of award numbers Federal Award Year: Various – See schedule of award numbers Questioned Costs: None Compliance Requirement: Subrecipient Monitoring Condition Found: The University did not review single audit reports received from its subrecipients for the R&D Cluster program on a timely basis. The University’s policy requires review of the single audit reports received from its subrecipients within six months of the date of acceptance of the single audit report by the Federal Audit Clearinghouse (FAC). During our testing of a sample of single audit report reviews for 40 subrecipients (with expenditures of $31,826,626), we noted the University did not review the single audit reports for nine subrecipients (with expenditures of $4,812,867) within six months of the date of acceptance of the single audit report by the FAC. Upon further review, management evaluated all the single audit report reviews performed during fiscal year 2024 for its subrecipients of the R&D Cluster program (195 single audit reviews for subrecipients with expenditures of $81,358,862) and determined that the single audit reports for 70 subrecipients (with expenditures of $48,019,701) were not reviewed within six months of the date of acceptance of the single audit report by the FAC. Specifically, these single audit reports were reviewed 181-392 days after acceptance by the FAC. The University’s subrecipient expenditures under the R&D Cluster program for the year ended June 30, 2024 were $81,358,862. Criteria: According to 2 CFR 200.332(e), a pass-through entity is required to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Further, 2 CFR 200.332(e)(3) and 2 CFR 200.521 state that a pass-through entity is required to issue a management decision for audit findings pertaining to the Federal Award provided to the subrecipient from the pass-through entity within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC) and ensure that the subrecipient takes timely and appropriate corrective action on all audit findings. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Effective internal controls should include procedures to ensure single audit reports are reviewed in a timely manner in accordance with University policy. Cause: In discussing these conditions with University officials, they stated this delay was an oversight due in part to limited staffing resources to review the single audits while the University was implementing a new financial system. Possible Asserted Effect: Failure to complete and document reviews of subrecipient single audit reports in a timely manner may result in federal funds being expended for unallowable purposes and subrecipients not administering the federal programs in accordance with laws, regulations, and grant agreements. Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the University establish procedures to ensure subrecipient single audit report reviews are completed and documented in a timely manner. Views of University Officials The University concurs with the finding and has already begun to address these concerns. Although there was a delay in the review of single audit reports, the University did not miss or delay any required action with said subrecipients as a result. See separate report for planned corrective action.
2024-003 HOME Investment Partnerships, ALN 14.239 Federal Award Identification Number and Year: MC-DC250213, 2022-2030 Award Period: September 16, 2022 through September 1, 2030 Compliance Requirement: Subrecipient Monitoring Criteria or Specific Requirement: CFR Title 2 section 200.332(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes, amongst other required information, the subrecipients’ unique entity number (UEI). 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. Condition and Context: For three (3) of five (5) subrecipients out of five in our audit sample, the subrecipients’ UEI’s were not included in the subaward document. Questioned Costs: None. Cause: Procedures were not implemented to ensure subrecipient UEI's were accurate and properly included in the subaward documents. Effect: Noncompliance with federal requirements occurred. Repeat Finding: No. Recommendation: We recommend procedures be strengthened to ensure accurate UEI's are obtained and included within subaward documents. Views of Responsible Officials: Management agrees with the finding.
Finding 2024-001 U.S. Department of Housing and Urban Development Assistance Listing Number 14.239 – Home Investment Partnership Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-001 U.S. Department of Housing and Urban Development Assistance Listing Number 14.239 – Home Investment Partnership Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-001 U.S. Department of Housing and Urban Development Assistance Listing Number 14.239 – Home Investment Partnership Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-001 U.S. Department of Housing and Urban Development Assistance Listing Number 14.239 – Home Investment Partnership Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-001 U.S. Department of Housing and Urban Development Assistance Listing Number 14.239 – Home Investment Partnership Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-001 U.S. Department of Housing and Urban Development Assistance Listing Number 14.239 – Home Investment Partnership Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-002 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Significant Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2023-003 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-002 U.S. Department of the Treasury Assistance Listing Number 21.027 – COVID-19 - American Rescue Plan Act Funds (US Treasury ARPA) Significant Deficiency over Subrecipient Monitoring Repeat Finding: Yes, 2023-003 Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 3 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
Finding 2024-003 Small Business Administration Assistance Listing Number 59.059– Inclusive Venture Program Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 1 out of 1 selection, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report.
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
U.S. Department of the Health and Human Services Assistance Listing Number 93.959 – Block Grants for Substance Use Prevention, Treatment, And Recovery Services Significant Deficiency over Subrecipient Monitoring Repeat Finding: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). Condition and Context: For 2 out of 2 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County not to be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County prepare and maintain a written plan to ensure subrecipients are aware of the Uniform Guidance requirements. Views of Responsible Officials: Management agrees with the finding. Refer to the Corrective Action Plan Section of this report
Finding 2024-002: Subrecipient Monitoring - Risk Assessment Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: In accordance with 2 CFR 200.332(b), Asian University for Women (AUW) Support Foundation should 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 paragraph (e) of this section, which may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) whether the subrecipient has new personnel or new or substantially changed systems; and (4) the extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200. Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed. Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b). Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls. Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Finding 2024-004: Identifying the Award and Applicable Requirements Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: As codified in 2 CFR Part 200.332, requires prime awardees awarded a federal grant to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (2) all requirements imposed by the pass-through entity (PTE) on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award. Condition: We tested subrecipient awards and found that there were no official subrecipient grant letters identifying the award and its applicable requirements. Questioned Costs: No questioned costs identified. Context: This is a condition identified during our testing of the compliance requirements for subrecipient monitoring. This internal control matter could result in noncompliance with certain federal awards. Cause: Asian University for Women (AUW) identifying the award and applicable requirements and described in 2 CFR section 200.332 Effect: Failure to comply with the 2 CFR section 200.332 requirements may put the grant funding at risk due to noncompliance under the Uniform Guidance. Recommendation: We recommend management immediately update its procedures to provide subrecipients with official grant letters that include the requirements under 2 CFR section 200.332. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan
Finding No. 2024-007: Inadequate Internal Controls over Monitoring of Subrecipient Audits Type of Finding: Significant Deficiency and Non-Compliance Assistance Listing Title: Disaster Grants - Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Federal Award Number: 4155DRSDP00000001,4440DRSDP00000001, 4463DRSDP00000001, 4467DRSDP00000001, 4469DRSDP00000001, 4527DRSDP00000001, 4656DRSDP00000001, 4664DRSDP00000001, 4689DRSDP00000001, and 4718DRSDP00000001 Federal Award Year: 2019, 2020, 2021, 2022, 2023, and 2024 Federal Agency: Department of Homeland Security Category of Finding: Subrecipient Monitoring Criteria: 2 CFR section 200.332 requires, among other things, that a pass-through entity verify that subrecipients receive Single Audits as required by 2 CFR 200.501(a), follow-up to ensure that the subrecipient takes timely and appropriate action on audit findings, and issue a management decision on applicable audit findings pertaining to the subaward. 2 CFR 200.521(d) requires this management decision to be issued within six months of acceptance of the audit report by the Federal Audit Clearinghouse (FAC). Condition: The Department of Public Safety (DPS) receives funding under ALN 97.036, Disaster Grants - Public Assistance (Presidentially Declared Disasters) (Public Assistance) and makes subawards to local governments and private nonprofit entities to respond to and recover from presidentially declared disasters. During FY24, DPS did not have adequate controls in place to ensure that Single Audits were obtained for all applicable subrecipients within the required time frame, that those audits were reviewed to ensure timely and appropriate action was taken on any findings, and that a management decision was issued by DPS within the six-month time frame required by federal regulations. Based on our review of funding amounts passed through by DPS, there were seven subrecipients receiving Federal grant payments that would require a Single Audit for the auditee’s fiscal year 2023. These subrecipients had received the required audits and their audit reports were accepted by the FAC, however, two of the audits were not reviewed timely by DPS. Of those two subrecipient audits, one had an audit finding pertaining to the Public Assistance program and DPS had not issued a management decision within the time frame required by 2 CFR 200.521. Cause: Controls were not adequate to identify when subrecipient audits were due and obtain all required audits off the FAC in a timely manner. While DPS personnel did track expenditures to determine which subrecipients were required to have audits under 2 CFR 200.501(a), failure to monitor subrecipient year-ends and the related audit deadlines resulted in some audits not being obtained and reviewed in a timely manner. Effect: This resulted in noncompliance with subrecipient monitoring requirements and increased the risk of subrecipient audit findings not being corrected in a timely manner. Questioned Costs: None. Repeat Finding from Prior Year: No. Recommendation: We recommend the Department implement controls to ensure that audits of subrecipients are obtained and followed up on in a timely manner and that management decisions are issued within the required time frame for all audit findings pertaining to DPS subawards. Views of Responsible Officials: The Department of Public Safety concurs with the audit finding.
Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Finding 2024-004 – Subrecipient Monitoring — Material Weakness Department of Health and Human Services Research and Development Cluster National Science Foundation, Assistance Listing No. 47.076 (STEM Education) Federal award year 2023-2024 Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that risk assessment and monitoring are formally documented over subrecipient monitoring. In accordance with 2 CFR 200.332(b) and 2 CFR 200.332(e), a pass-through entity is required to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of each sub-award for purposes of determining appropriate subrecipient monitoring requirements. Depending on the risk assessment, the pass-through entity should identify monitoring procedures to be performed in order to ensure proper accountability and compliance with program requirements and achievements of performance goals. Condition: The University’s controls were not operating effectively to reasonably ensure the University performed risk assessment and monitoring procedures for its subrecipients. As a result, the University did not comply with the compliance requirements for subrecipient monitoring. Cause: The University does not have processes and procedures in place related to risk assessment and subrecipient monitoring. Effect or potential effect: The University is not in compliance with federal grant requirements over subrecipient monitoring. Lack of properly documented evidence of subrecipient monitoring policies and procedures performed, including required risk assessments, could result in actions taken by oversight agencies which could impact future funding. Questioned costs: None Context: The University has two active awards under the program with subrecipients with an aggregate award value of approximately $71,000. The University has two subrecipients and for both subrecipients tested in the major program, there was no evidence that a risk assessment or monitoring of those subrecipients was performed. Identification as a repeat finding, if applicable: Not applicable. Recommendation: We recommend the University develop processes and procedures to perform the required risk assessments and related monitoring, and maintain support that the risk assessments and related monitoring were performed as required. View of responsible officials: Management agrees with this finding. See corrective action plan.
Reference Number: 2024-002 Prior Year Finding: 2023-007 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.332 – Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Verify that every subrecipient is audited as required by Subpart F – Audit Requirements of this part when it is expected that the subrecipient’s Federal award expended during the respective fiscal year equaled or exceeded the threshold set forth in section 200.501 Audit requirements. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a 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 statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County was not able to provide documentation to show it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F – Audit Requirements (Subpart F). Context: Exceptions were noted for 7 of 7 subrecipients selected for testing: • The County was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The County could not produce evidence of verification that the subrecipient’s Federal awards expended during the fiscal year were below the threshold set forth in section 200.501 Audit Requirements. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple years, and these discrepancies may not be properly monitored, detected, and corrected by the County personnel on a timely basis. Questioned Costs: Undetermined. Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2024-002 Prior Year Finding: 2023-007 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.332 – Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Verify that every subrecipient is audited as required by Subpart F – Audit Requirements of this part when it is expected that the subrecipient’s Federal award expended during the respective fiscal year equaled or exceeded the threshold set forth in section 200.501 Audit requirements. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a 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 statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County was not able to provide documentation to show it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F – Audit Requirements (Subpart F). Context: Exceptions were noted for 7 of 7 subrecipients selected for testing: • The County was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The County could not produce evidence of verification that the subrecipient’s Federal awards expended during the fiscal year were below the threshold set forth in section 200.501 Audit Requirements. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple years, and these discrepancies may not be properly monitored, detected, and corrected by the County personnel on a timely basis. Questioned Costs: Undetermined. Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Condition – For five out of six subawards, the Department did not include identification of whether the award is research and development or indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. These contracts also did not include the subrecipient’s Unique Entity Identifiers, nor the Federal Award Date. Cause – At the time the tested agreements were established, the Department had not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients would result in grantee’s not being aware of their current indirect cost rate allowance, or if the award was for R&D purposes. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements. Conclusion – Response accepted.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Condition – For five out of six subawards, the Department did not include identification of whether the award is research and development or indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. These contracts also did not include the subrecipient’s Unique Entity Identifiers, nor the Federal Award Date. Cause – At the time the tested agreements were established, the Department had not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients would result in grantee’s not being aware of their current indirect cost rate allowance, or if the award was for R&D purposes. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements. Conclusion – Response accepted.
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes identification of whether the award is research and development and the indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. Condition – For five out of six subawards, the Department did not include identification of whether the award is research and development or indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. These contracts also did not include the subrecipient’s Unique Entity Identifiers, nor the Federal Award Date. Cause – At the time the tested agreements were established, the Department had not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients would result in grantee’s not being aware of their current indirect cost rate allowance, or if the award was for R&D purposes. Recommendation – The Department should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response and Corrective Action Planned – Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements. Conclusion – Response accepted.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.
2024-009 Program: Aging Cluster Federal Financial Assistance Listing Number: 93.041, 93.042, 93.043, 93.044, 93.045, 93.052, 93.053 Federal Grantor: U.S. Department of Health and Human Services Passed-Through: California Department of Aging Award No. and Year: AP-2122-22 and 2022, AP-2324-22 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: Per 2 CFR 200.332, a pass-through entity must 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 include the information at 2 CFR 200.332(1) through (4). Condition: During our testing of the Orange County Community Resources (OCCR) department’s provisions for subrecipient monitoring requirements, we noted that for one (1) of four (4) subrecipients tested, onsite monitoring and follow-up on documented deficiencies was not performed timely. Cause: Established policies and procedures related to subrecipient monitoring do not specify the timeframe within which monitoring must be completed. Effect: There is an increased risk that the department’s monitoring procedure may not address the subrecipient’s risk of noncompliance. Question Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A non-statistical sample of four (4) out of (10) subrecipients were selected for testing. The condition above was identified during our procedures over subrecipient monitoring. Repeat Finding: No. Recommendation: We recommend the department review its established policies and procedures to ensure subrecipient monitoring is performed timely. Views of Responsible Officials: Management agrees. See separately issued Corrective Action Plan.