Post-closeout adjustments and continuing responsibilities.
2025-002 – Subrecipient Monitoring Federal program information: Funding Agency: U.S. Department of the Interior; Bureau of Indian Education Title: Indian Education Assistance to Schools Assistance Listing Number: 15.130 Award Period: December 9, 2024 – December 8, 2026 Criteria: Uniform Guidance regulations section 2 CFR 200.332(b) require a pass-through entity to ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the federal award identification information listed at 2 CFR 200.332(b)(1). That information includes the subrecipient's unique entity identifier, the Assistance Listing Number and title, and the subaward budget period start and end date. Where any of that information is unavailable at the time of the subaward, the pass-through entity must provide the best available information and must provide the unavailable information when it is obtained. Condition: NFEAIE issued eight subawards totaling $6,635,000 during the year ended December 31, 2025. The Assistance Listing Number and title were not stated in any of the eight executed subaward agreements or their attachments. The subaward budget period was not stated in any of the eight agreements. The subrecipient's unique entity identifier was not stated in three agreements totaling $2,238,547. Context: Eight subawards tested, representing 100% of the subrecipient population and 96% of total federal expenditures for the year. Questioned Costs: None. Cause: The subaward template was drafted without comparing it to the information required by 2 CFR 200.332(b)(1). NFEAIE has no written procedure requiring executed subaward agreements to be reviewed against that information before execution. Effect: NFEAIE did not comply with 2 CFR 200.332(b)(1). A subrecipient that is not given the Assistance Listing Number may report the award incorrectly or omit it from its own schedule of expenditures of federal awards, which affects the subrecipient's major program determination and audit coverage, and may also affect subaward reporting under the Federal Funding Accountability and Transparency Act. Omission of the unique entity identifier removes the identifier used to match the subaward to the subrecipient's registration. Auditors' Recommendation: NFEAIE should amend each of the eight executed subaward agreements to add the Assistance Listing Number and title, the subaward budget period, and the unique entity identifier where it was omitted, and should provide the amended agreements to each subrecipient. NFEAIE should adopt a written subaward issuance procedure that includes a checklist of the information required by 2 CFR 200.332(b)(1), completed and retained in the subaward file before execution, and should update the subaward template before the second round of awards is issued. Management's Response: Management concurs with the condition described. Three of the federal award identification elements required by 2 CFR 200.332(b)(1) were omitted from the Round 1 subaward instruments. There are no questioned costs. The Round 1 instruments identified the subrecipient, the Federal Award Identification Number, the federal award date, the subaward period of performance, the total amount of the subaward, the federal award project description, the pass-through entity and its contact, the research and development determination, and the applicable indirect cost rate. They flowed down the Uniform Guidance cost principles and administrative requirements, records retention and audit access under 2 CFR 200.334 and 200.337, closeout obligations under 2 CFR 200.344 and 200.345, the nonprocurement suspension and debarment certification, and quarterly and annual reporting requirements. The omission was limited to the Assistance Listing Number and title, the subaward budget period, and, in three instruments, the unique entity identifier. Before making any subaward, NFEAIE evaluated forty applications through a competitive process, each scored independently by three reviewers, and conducted entity-level financial and compliance due diligence on applicants advancing to award consideration. Four applicants were declined or deferred on the basis of that review. NFEAIE has monitored the subawards throughout the period of performance. The Round 1 template was prepared in the organization’s first months of operation and was not checked against the data element list at 2 CFR 200.332(b)(1). NFEAIE corrected the template in September 2026. The corrected form was used for the subaward executed September 18, 2026 and carries the full element set, together with specific conditions imposed under 2 CFR 200.208 for subrecipients designated elevated risk. The remaining remediation is set out below.