Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Cluster name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award numbers and years: DI21-002286, April 1, 2022 through June 30, 2024; Alert 23-001, July 1, 2023 through June 30, 2024; Alert 23-003, July 1, 2023 through June 30, 2024; Alert 24-002, July 1, 2023 through May 31, 2024 Federal agency: U.S. Department of Labor Pass-through grantor: Arizona Department of Economic Security Questioned costs: N/A Assistance Listings number and name: 21.027 COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Award numbers and years: 1505-0271, March 3, 2021 through December 31, 2024; 19418, May 31, 2023 through September 30, 2023 Federal agency: U.S. Department of the Treasury Pass-through grantors: Arizona Criminal Justice Commission, City of Tucson, Arizona Housing Coalition, and Arizona Department of Public Safety Questioned costs: N/A Assistance Listings number and name: 97.024 COVID-19 - Emergency Food and Shelter National Board Program Award numbers and years: 027200-048, November 1, 2021 through December 30, 2024; 027200-056, April 1, 2023 through February 29, 2024; 23*115, March 1, 2023 through February 29, 2024; 23*154, April 1, 2023 through February 29, 2024 Federal agency: U.S. Department of Homeland Security Pass-through grantor: United Way EFSP Questioned costs: $347,345 Assistance Listings number and name: 97.141 Shelter and Services Program Award number and year: 24*039, March 1, 2023 through September 30, 2025 Federal agency: U.S. Department of Homeland Security Questioned costs: N/A Compliance requirement: Subrecipient monitoring Total questioned costs: $347,345 Condition—The County’s Grants Management and Innovation Department (Department) awarded over $29 million to 27 subrecipients during fiscal year 2024, or 29% of the County’s total federal expenditures for the federal programs shown in Table 1 below, but did not perform all the required monitoring of its subrecipients’ activities or compliance with award terms and program requirements. Table 1 Summary of subrecipients by federal program Fiscal year 2024 Federal program name Subrecipient information Total number Number tested Total awards Total federal expenditures Subrecipient awards as a percentage of total federal expenditures Workforce Innovation and Opportunity Act (WIOA) Cluster 4 4 $ 568,095 $12,253,972 4.6% Coronavirus State and Local Fiscal Recovery Funds (SLFRF) 17 7 17,241,445 56,862,338 30.3% Emergency Food and Shelter National Board Program (EFS) 4 4 7,810,673 22,622,229 34.5% Shelter and Services Program (SSP) 2 2 3,560,449 8,172,063 43.5% Total 27 17 $29,180,662 $99,910,602 29.2% While the Department performed some monitoring procedures during the year, those procedures were not sufficient to evaluate its subrecipients’ use of program monies in accordance with the award terms, program requirements, and federal regulations. Specifically, contrary to federal regulations, the Department did not perform the following required monitoring procedures: • Perform monitoring activities based on risk assessments performed—The Department did not perform monitoring activities based on risk assessments performed. Specifically, the Department’s risk assessment procedures identified 7 high-risk and 4 moderate-risk subrecipients, but it did not modify its monitoring activities to address the risks identified. Additional monitoring activities could include providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures like reviewing the subrecipient’s policies and procedures obtained to ensure the subrecipients complied with award terms, program requirements, and federal regulations. • Document monitoring procedures, results, and actions taken—For 4 of 4 WIOA subrecipients, 7 of 7 SLFRF subrecipients, 3 of 4 EFS subrecipients, and 1 of 2 SSP subrecipients we tested, while the Department completed and maintained a checklist of subrecipient monitoring procedures, it did not document monitoring results or Department actions taken for these subrecipients based on the checklist results. • Verify subrecipient single audits were conducted timely—The Department did not verify whether 1 of its 4 WIOA subrecipients had a single audit performed. Effect—The Department’s failure to perform required monitoring contributed to $347,345 of misspent EFS program monies that the Department may be required to return to the federal agency in accordance with federal requirements.1 Specifically, the Department’s not reviewing subrecipient procurement policies and procedures aided in allowing 1 EFS subrecipient to render services for which conflicts of interest existed. Specifically, the EFS subrecipient, Catholic Community Services (CCS), began having laundry services provided by a vendor, Amado Laundry, in April 2023, for which it then self-reported to the County a conflict-of-interest violation in May 2024. This violation was a result of a CCS employee forming a vendor relationship with Amado Laundry, which was owned by the employee’s mother. After the Department’s management was made aware of the conflict of interest, they performed monitoring procedures over CCS and identified noncompliance with federal procurement guidelines totaling $347,345, including determining that Amado Laundry charged a rate double the average rates charged by competitors. The County issued a management letter to CCS on September 27, 2024, communicating a conflict-of-interest finding and a procurement standards finding. The conflict-of-interest finding required CCS to develop new, written procurement-related conflict-of-interest procedures in compliance with federal regulations and to create and maintain an ongoing training program related to these federally compliant conflict-of-interest procedures for employees. Further, there is an increased risk that $29 million of program monies the Department awarded to subrecipients may not be spent in accordance with the award terms, program requirements, and federal regulations. If monies are spent inconsistent with program requirements, those who intended to benefit from the program may not receive all the services or other benefits they otherwise would have received. Also, the Department’s not verifying subrecipient single audits were conducted may result in the Department’s not following up on and ensuring corrective action is taken on audit findings that could potentially affect the program and/or issue management decisions for audit findings pertaining to the federal award. Finally, the County is at risk that this finding applies to other federal programs it administers. Cause—The Department’s management reported that they did not always follow County policies and procedures and only performed limited procedures because their subrecipient monitoring policies and procedures were outdated, the number of subrecipients increased significantly during the fiscal year, and they did not have sufficient staff to monitor all subrecipients. The Department’s management also reported that it prioritized transitioning to a new enterprise resource planning (ERP) system rather than monitoring all subrecipients. Further, the County’s policies lacked requirements to perform monitoring activities based on risk assessments performed and to review subrecipients’ policies and procedures to ensure the subrecipients complied with award terms, program requirements, and federal regulations. Criteria—Federal regulation requires the County to monitor subrecipients, which includes required monitoring procedures for (2 CFR §200.332): • Assessing the risk of each subrecipient’s noncompliance and performing monitoring activities based on those risk assessments, such as providing training or technical assistance on program-related matters and performing on-site reviews, selective audits, and/or other monitoring procedures. • Reviewing financial and performance reports. • Verifying single audits were conducted timely. • Following up on and ensuring corrective action is taken on audit findings that could potentially affect the program. • Issuing a management decision for audit findings pertaining to the federal award. In addition, County policies require the County to: • Assess subrecipient risk and establish a monitoring plan and perform monitoring procedures at least every 2 years, including verification of internal controls.2,3 • Review the Federal Audit Clearinghouse at least quarterly to review subrecipient single audits and issue management decision letters, as necessary.2 • Maintain documentation of monitoring procedures, including the monitoring procedure’s results and any Department actions taken.3 Further, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations to the County— 1. Perform required monitoring of its subrecipients and their compliance with the award terms, program requirements, and federal regulations. 2. Follow its established policies and procedures for performing and documenting monitoring reviews of subrecipients to: a. Maintain documentation of monitoring procedures demonstrating they were performed, including the monitoring procedures’ results and any Department actions taken, if appropriate. b. Verify subrecipients receive timely single audits, follow up on and ensure that corrective action is taken on audit findings that could potentially affect the program, and issue management decisions for audit findings pertaining to the federal award. 3. Update its policies and procedures to include: a. A process to determine the appropriate monitoring activities to perform based on subrecipient risk assessments performed, such as providing training or technical assistance on program-related matters, and performing on-site reviews, selective audits, and/or other monitoring procedures. b. Review subrecipients’ policies and procedures, including procurement processes, to ensure the subrecipients complied with award terms, program requirements, and federal regulations. 4. Prioritize and allocate sufficient resources, such as staffing, to comply with the award terms, program requirements, federal regulations, and its updated policies, and designate an individual(s) to perform necessary subrecipient-monitoring procedures. 5. Work with U.S. Department of Homeland Security to determine if it will require the Department to reimburse $347,345 in questioned costs. The County’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-101 and was initially reported in fiscal year 2022. 1 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521). 2 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-04: Subrecipient Risk Assessment / Management Decisions. 3 Pima County. (2018, June). Grants Management & Innovation Policy number GMI-28: Subrecipient Monitoring.
Finding 2024-003: Subrecipient Management and Monitoring (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Additionally, per 2 CFR 200.332(a), pass-through entities must include specific information in subrecipient agreements, such as the Assistance Listing Number (ALN), compliance requirements, and monitoring responsibilities, to ensure proper oversight and accountability. Condition: Astraea has a subaward policy, which requires a risk assessment form be completed for each potential subrecipient. However, this step was not completed for all of the subrecipients in which Astraea engaged with during the fiscal year. Furthermore, during our review of subrecipient agreements, we noted that certain agreements did not contain all the required elements as outlined in 2 CFR 200.332(a). Cause: Astraea did not adhere to its policy in regards to risk assessment procedures. Additionally, Astraea did not have formalized procedures for ensuring all required elements, including the ALN, were included in subrecipient agreements. Context: Astraea failed to perform risk assessment procedures. Our audit work in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. The issue is deemed to be systemic. Additionally, during our review of subrecipient agreements we noted two that did not include the required ALN, which is necessary to properly identify the source of Federal funding. Effect: Astraea could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Additionally, the absence of required information in subrecipient agreements increases the risk of noncompliance with Federal grant requirements and improper use of Federal funds.Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: Finding 2023-004 Recommendation: We recommend Astraea adhere to its current subaward policy and ensure the risk assessment procedures over all of its subrecipients are performed and documented prior to engagement. Based on these risk assessments, Astraea should assign a risk level to each, and then determine the monitoring tools to apply based on these risk levels. We also recommend Astraea require its subrecipients to submit financial reports demonstrating use of each advance before advancing more funds, to ensure subrecipients are expending funds appropriately. Furthermore, Astraea should implement enhanced review procedures to ensure all subrecipient agreements include the required information before execution, such as, updating standard agreement templates.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-014 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Condition: For 2 out of 2 selections, there is no evidence that the subrecipients were monitored during the fiscal year. For 2 out 2 selections, various information related to the funding source and the pass through entity were missing on the notice of award (E.g. FAIN number, UEI, indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.(f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: MOHS did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: The City may not be in compliance with the Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-016 U.S. Department of Health and Human Services AL No. 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Condition: For 1 out of 1 selection, management was unable to provide the notice of award. For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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 d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. According to AM 413-60, Grant Documentation, Grant Manager/Program Manager/Director Conducts ongoing monitoring and control of all reimbursement receipts and deposits until grant ends; as well as all program and sub-recipient (when applicable) documentation, to include: (1) program documentation; (2) timesheets; (3) deliverables; (4) activities; (5) vendor payments; (6) program data/charts/numbers; and (7) financial and compliance report. According to AM 413-61, Grant Management Financial Reporting, Grant Manager/Program Manager/Director maintains all documentation, either electronic or hard copy, for all Federally funded grants for the term of the grant for a minimum of seven years for review and audit by the granting agency or its designee. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-018 U.S. Department of Health and Human Services AL No. 93.600 Head Start Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Condition: For 1 out of 1 selection, various information related to the funding source and the pass-through entity is missing on the notice of award (E.g. FAIN number, UEI and indirect cost). Criteria: In accordance with 2 CFR §200.303: The non-federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. Cause: MOCFS did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: MOCFS may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, management was unable to provide the notice of award. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, management was unable to provide the notice of award. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, management was unable to provide the notice of award. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, management was unable to provide the notice of award. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, management was unable to provide the notice of award. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, management was unable to provide the notice of award. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Condition: For 6 out of 6 selections, we were unable to verify the subrecipient's active registration on SAM.gov. For 6 out of 6 selections, various information related to the funding source and the pass through entity is missing on the notice of award (E.g. FAIN number, UEI, CFDA and name of pass-through and indirect cost). For 3 out of 6 selections, there were either findings identified during site visit or on the fiscal year 2023 single audit report of the subrecipient. However, no documentation was provided to evidence follow-up or other documentation to ensure that the identified issues were resolved. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (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. d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: BCHD did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD may not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.