Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. 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. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part 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. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. 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. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part 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. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D?Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from subrecipients being identified as vendors in the grant application. Also, the Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. EFFECT Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH?s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the current audit period, we noted 27 subrecipients were awarded funds. During our review of 6 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support DPH?s evaluation of each subrecipients risk of noncompliance and the frequency of monitoring to be conducted by DPH based on the assessed risk. Also, we noted no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including DPH?s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONTEXT (Continued) In addition, while we noted that DPH does have a draft policy manual regarding the monitoring of its subrecipients, we noted the manual does not currently address or include the process and related procedures for conducting both fiscal and programmatic monitoring. Specifically, the draft manual does not: a) include any related checklists and/or forms being utilized, b) address the performance of risk assessments, or c) detail the frequency and type of monitoring (i.e., desk review, site visit) to be conducted based on assessed risks. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332 and once updated the draft policy should be finalized and implemented. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 64.
Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D?Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONDITION During the current audit period, the Cook County Department of Public Health (DPH) did not perform adequate monitoring of its subrecipients as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding resulted from subrecipients being identified as vendors in the grant application. Also, the Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. EFFECT Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and DPH?s inability to adequately perform risk assessments on its subrecipient(s). QUESTIONED COSTS None. CONTEXT During the current audit period, we noted 27 subrecipients were awarded funds. During our review of 6 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support DPH?s evaluation of each subrecipients risk of noncompliance and the frequency of monitoring to be conducted by DPH based on the assessed risk. Also, we noted no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including DPH?s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). SECTION III: FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS (Continued) Subrecipient Monitoring Federal Department ? U.S. Department of Health and Human Services Federal Award Identification Number and Year: NH75OT000024 and 2021 COVID-19 - Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises, Federal Assistance Listing # 93.391 County Department ? Department of Public Health Finding 2022 ? 009 (Continued) CONTEXT (Continued) In addition, while we noted that DPH does have a draft policy manual regarding the monitoring of its subrecipients, we noted the manual does not currently address or include the process and related procedures for conducting both fiscal and programmatic monitoring. Specifically, the draft manual does not: a) include any related checklists and/or forms being utilized, b) address the performance of risk assessments, or c) detail the frequency and type of monitoring (i.e., desk review, site visit) to be conducted based on assessed risks. IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend DPH update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332 and once updated the draft policy should be finalized and implemented. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County?s corrective action plan is on page 64.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (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 in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Department of Environmental Protection Finding 2022 ? 005: ALN 15.252 ? Abandoned Mine Land Reclamation A Material Weakness and Material Noncompliance Exist at the Department of Environmental Protection Related to Subrecipient Monitoring (A Similar Condition Was Noted in Prior Year Finding 2021-004) Federal Grant Number(s) and Year(s): S21AF10015 (01/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 09/30/2023), S20AF20006 (01/01/2020 ?? 12/31/2022), S19AF20006 (01/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2022), S18AF20004 (11/01/2017 ?10/31/2023) Type of Finding: Material Weakness, Material Noncompliance Compliance Requirement: Subrecipient Monitoring Condition: The Department of Environmental Protection (DEP) administers the Abandoned Mine Land Reclamation (AMLR) program funded by the United States Department of the Interior (DOI). During the fiscal year ended June 30, 2022, DEP expended $49,400,302 within the AMLR program, of which $13,270,381 was paid to 18 subrecipients with whom DEP executed subrecipient agreements to provide abandoned mine land reclamation repairs and services throughout Pennsylvania. Our audit testing disclosed that DEP did not conduct risk assessments or program monitoring of these subrecipient expenditures during the fiscal year ended June 30, 2022, since DEP considered these entities to be contractors and not subrecipients. Based on a recent determination made by DEP, these entities should be categorized as subrecipients. As such, DEP began implementing procedures to ensure federal regulations are met regarding subrecipient agreements. However, these procedures were implemented subsequent to the fiscal year ended June 30, 2022. While Single Audits of the AMLR subrecipients may be conducted each year, this auditing activity does not compensate for the lack of during-the-award program monitoring, since the timing, focus, and scope of subrecipient auditing activities after year end are different than compliance monitoring to be performed by program officials during the year. Criteria: As part of administering the AMLR program, DEP must have policies, procedures, and controls in place to ensure compliance with federal requirements within contract requirements and regulations. 2 CFR Section 200.332, Requirements for pass through entities, states in part: All pass-through entities must: (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 [Management decision]. Finding 2022 ? 005: (continued) (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425 [Audit services]. The standard contract agreement between DEP and the local grantee states, in part: Audit/Compliance Review Requirements - The contractor must comply with all applicable federal and state grant requirements including the Single Audit Act Amendments of 1996; 2 CFR Part 200 as amended; and any other applicable law or regulation, and any amendment to such other applicable law or regulation that may be enacted or promulgated by the federal government. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: In previous years, DEP management considered these entities as contractors for whom subrecipient monitoring requirements were not applicable. However, based on recent determinations, DEP acknowledges these entities as subrecipients, not contractors, subject to federal subrecipient requirements. Effect: Without the completion of risk assessments and subrecipient monitoring, DEP cannot ensure compliance with federal statutes, regulations, and the terms and conditions of the subrecipient contracts, confirm that local subrecipients are performing satisfactory work, ensure the efficient use of program resources, and minimize the risk for fraud and abuse. Completing monitoring activities is essential for DEP to determine whether the local agencies are complying with federal regulations and spending grant funds appropriately. Recommendation: We recommend that DEP continue to develop and implement written policies and procedures for performing risk based during-the-award subrecipient monitoring and implement them immediately to ensure timely subrecipient compliance with federal regulations. On-site monitoring visits by state officials should be supported by documentation to show the monitoring performed, areas examined, conclusions reached, and that the monitoring was performed in compliance with applicable regulations. Agency Response: The Department of Environmental Protection agrees with the facts as presented in this finding. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Department of Human Services Finding 2022 ? 008: ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2021-007) Federal Grant Number(s) and Year(s): 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 1801PATANF (10/01/2017 ? 9/30/2018), 1701PATANF (10/01/2016 ? 9/30/2017) Type of Finding: Significant Deficiency, Noncompliance Compliance Requirement: Subrecipient Monitoring Condition: During the fiscal year ended June 30, 2022, the Department of Human Services (DHS) paid $79.5 million in Temporary Assistance for Needy Families (TANF) funding to subrecipients within the New Directions, Cash Grants, and Alternatives to Abortion appropriations (or 22.1 percent) out of total federal TANF expenditures of $360.2 million reported on the June 30, 2022 Schedule of Expenditures of Federal Awards. Our testing of DHS?s during-the-award monitoring of subrecipients for the fiscal year ended June 30, 2022 disclosed that DHS performed on-site monitoring for 20 out of 21 subrecipients selected for testing. The on-site monitoring that was performed consisted of reviews of program operations including design, data entry accuracy and timeliness, case management analysis, and program payment performance goals. The on-site monitoring also included a review of a sample of TANF recipient case files to ensure that the recipients? TANF activities were documented and accurately entered in the Commonwealth?s Workforce Development System. However, DHS?s monitoring procedures for the 20 subrecipients were not adequate as they did not include a review or monitoring of subrecipient financial records, which would provide an assessment of a subrecipient?s compliance with applicable federal regulations. Although DHS?s monitoring procedures include reviewing subrecipient completed questionnaires for selected subrecipients that had questions related to financial matters, DHS?s monitoring personnel did not review subrecipient financial records. For example, DHS did not perform procedures to ensure subrecipient invoices agreed to the books and records of the subrecipient and that the records were adequate to support the allowability of costs paid by DHS during the award period. In addition, DHS?s monitoring procedures did not include an evaluation of the operating effectiveness of DHS subrecipients? procedures to monitor Single Audits and any related findings. Our testing of the 21 subrecipients noted above included follow up on one subrecipient identified in the prior year finding as not being on-site monitored by DHS when the risk assessment warranted on-site monitoring. Our follow-up during the current audit period disclosed that DHS did not conduct on-site monitoring for this subrecipient during the fiscal year ended June 30, 2022. Since the on-site monitoring was not completed, internal control weaknesses, noncompliance, and questioned costs may have existed and remained undetected during the current audit period. This subrecipient received $980,923 of TANF funds during the fiscal year ended June 30, 2022. Criteria: 45 CFR Section 75.352, Requirements for pass-through entities, states: All pass-through entities must: (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. Finding 2022 ? 008: (continued) (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 75.521 [Management decision]. 2 CFR Section 200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425 [Audit services]. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: DHS planned to implement new during-the-award monitoring procedures to be used for the on-site monitoring of subrecipients, but these procedures were not in place for monitoring conducted during the fiscal year ended June 30, 2022. Therefore, DHS has not implemented adequate during-the-award monitoring procedures of subrecipients to include testing of the financial records and the subrecipients? monitoring of Single Audits sufficient to ensure compliance with federal regulations. Regarding the one subrecipient for which on-site monitoring was not completed, DHS personnel stated that they are working with the subrecipient to obtain the necessary documentation to complete the on-site monitoring. Effect: TANF subrecipients could be operating in noncompliance with federal regulations without timely detection and correction by DHS management. Recommendation: DHS should strengthen its controls to ensure during-the-award monitoring of TANF subrecipients includes procedures to ensure that subrecipients are in compliance with applicable federal regulations. This should include examining subrecipients? financial records and ensuring that all required Single Audits were obtained by DHS subrecipients. Agency Response: DHS agrees with this finding. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Department of Human Services Finding 2022 ? 008: ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2021-007) Federal Grant Number(s) and Year(s): 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 1801PATANF (10/01/2017 ? 9/30/2018), 1701PATANF (10/01/2016 ? 9/30/2017) Type of Finding: Significant Deficiency, Noncompliance Compliance Requirement: Subrecipient Monitoring Condition: During the fiscal year ended June 30, 2022, the Department of Human Services (DHS) paid $79.5 million in Temporary Assistance for Needy Families (TANF) funding to subrecipients within the New Directions, Cash Grants, and Alternatives to Abortion appropriations (or 22.1 percent) out of total federal TANF expenditures of $360.2 million reported on the June 30, 2022 Schedule of Expenditures of Federal Awards. Our testing of DHS?s during-the-award monitoring of subrecipients for the fiscal year ended June 30, 2022 disclosed that DHS performed on-site monitoring for 20 out of 21 subrecipients selected for testing. The on-site monitoring that was performed consisted of reviews of program operations including design, data entry accuracy and timeliness, case management analysis, and program payment performance goals. The on-site monitoring also included a review of a sample of TANF recipient case files to ensure that the recipients? TANF activities were documented and accurately entered in the Commonwealth?s Workforce Development System. However, DHS?s monitoring procedures for the 20 subrecipients were not adequate as they did not include a review or monitoring of subrecipient financial records, which would provide an assessment of a subrecipient?s compliance with applicable federal regulations. Although DHS?s monitoring procedures include reviewing subrecipient completed questionnaires for selected subrecipients that had questions related to financial matters, DHS?s monitoring personnel did not review subrecipient financial records. For example, DHS did not perform procedures to ensure subrecipient invoices agreed to the books and records of the subrecipient and that the records were adequate to support the allowability of costs paid by DHS during the award period. In addition, DHS?s monitoring procedures did not include an evaluation of the operating effectiveness of DHS subrecipients? procedures to monitor Single Audits and any related findings. Our testing of the 21 subrecipients noted above included follow up on one subrecipient identified in the prior year finding as not being on-site monitored by DHS when the risk assessment warranted on-site monitoring. Our follow-up during the current audit period disclosed that DHS did not conduct on-site monitoring for this subrecipient during the fiscal year ended June 30, 2022. Since the on-site monitoring was not completed, internal control weaknesses, noncompliance, and questioned costs may have existed and remained undetected during the current audit period. This subrecipient received $980,923 of TANF funds during the fiscal year ended June 30, 2022. Criteria: 45 CFR Section 75.352, Requirements for pass-through entities, states: All pass-through entities must: (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. Finding 2022 ? 008: (continued) (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 75.521 [Management decision]. 2 CFR Section 200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425 [Audit services]. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: DHS planned to implement new during-the-award monitoring procedures to be used for the on-site monitoring of subrecipients, but these procedures were not in place for monitoring conducted during the fiscal year ended June 30, 2022. Therefore, DHS has not implemented adequate during-the-award monitoring procedures of subrecipients to include testing of the financial records and the subrecipients? monitoring of Single Audits sufficient to ensure compliance with federal regulations. Regarding the one subrecipient for which on-site monitoring was not completed, DHS personnel stated that they are working with the subrecipient to obtain the necessary documentation to complete the on-site monitoring. Effect: TANF subrecipients could be operating in noncompliance with federal regulations without timely detection and correction by DHS management. Recommendation: DHS should strengthen its controls to ensure during-the-award monitoring of TANF subrecipients includes procedures to ensure that subrecipients are in compliance with applicable federal regulations. This should include examining subrecipients? financial records and ensuring that all required Single Audits were obtained by DHS subrecipients. Agency Response: DHS agrees with this finding. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Reference Number: 2022-023 Prior Year Finding: 2021-018 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Opioid STR Assistance Listing Number: 93.788 Award Number and Year: H79TI083305 (9/30/2020 ? 9/29/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (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 in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it monitored its subrecipients. Context: For 4 of 8 subrecipients selected for testing, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Recommendation: The Division should review and enhance internal controls and procedures to ensure that proper subrecipient monitoring is conducted in accordance with Federal regulations. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (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 in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it furnished required information to its subrecipients at the time of subaward, monitored its subrecipients, or ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in four of eight subrecipients selected for testing (exceptions listed include multiple exceptions for some subrecipients): ? Four of eight subrecipient agreements were missing the following required information: Subrecipient?s Unique Identifier, Federal Award Identification Number (FAIN), Federal Award Date, Federal Award Project Description, Assistance Listing Number and Title. ? For one of eight subrecipients, the Division was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The Division could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. ? For four of eight subrecipients, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, also that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (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 in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it furnished required information to its subrecipients at the time of subaward, monitored its subrecipients, or ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in four of eight subrecipients selected for testing (exceptions listed include multiple exceptions for some subrecipients): ? Four of eight subrecipient agreements were missing the following required information: Subrecipient?s Unique Identifier, Federal Award Identification Number (FAIN), Federal Award Date, Federal Award Project Description, Assistance Listing Number and Title. ? For one of eight subrecipients, the Division was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The Division could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. ? For four of eight subrecipients, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, also that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Subrecipient Monitoring Material Weakness Material Noncompliance 2022-023 Strengthen Controls to Ensure Compliance with Subrecipient Monitoring Requirements. ALN Number 17.258, 17.259, 17.278- Workforce Innovation and Opportunity Act Federal Award No. NIA Federal Agency Department of Labor Pass-through Entity NI A Questioned Costs NI A Criteria Code of Federal Regulations (2 CFR ?200.332(f)) states all pass-through entities (PTE?s) must verify that every subrecipient is audited as required by Subpart F - Audit Requirements when it is expected that the subrecipient's Federal awards expended during the fiscal year equaled or exceeded the threshold?a non- Federal entity that expends $750,000 or more during the non-Federal entity?s fiscal year in Federal awards must have a single audit conducted?set forth in ? 200.501 Audit requirements. Code of Federal Regulations 2 CFR 200.332 (d) states to 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. Sec. 184(a)(4) of the Workforce Innovation and Opportunity Act states the State must conduct an annual on-site monitoring review of each local area?s compliance with 2 CFR part 200. Code of Federal Regulations 2 CFR 200.332 (e) states depending upon the passthrough entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425. Condition The Mississippi Department of Employment Security (MDES) does not efficiently or effectively review the required federal audits for Subrecipient Monitoring Requirements per 2 CFR 200.332 (f). For three out of thirteen subrecipients the agency did not maintain or provide the correct Single Audit or the determination if a Single Audit was required when requested. MDES does not appropriately ensure on-site monitoring is done in a timely manner. During review of ten subrecipients, auditor noted that all documented monitoring was done after the fiscal year was complete, the monitoring was not completed on-site, and the reports for the monitoring were provided back to the agency after the fiscal year was complete. Per discussion with agency personnel, a pre-award scoring is being performed to determine ability of the subrecipient to enact the grant, however a risk based assessment to ensure the subrecipient has proper accountability with the award is not being performed. Cause Staff did not follow policies and procedures for subrecipient on-site monitoring requirements. Effect Subrecipients could be in noncompliance with 2 CFR ? 200.501, Audit requirements, and go undetected by MDES. In addition, MDES could lose federal funding for not properly monitoring their subrecipients. Without proper monitoring of their federal reports, subrecipients may participate in unallowable activities that goes undetected by MDES, the grantor. Recommendation We recommend that the Mississippi Department Employment Security strengthen controls to ensure compliance with the Subrecipient Monitoring requirements. Repeat Finding No. Statistically Valid No.
Department of Environmental Protection Finding 2022 ? 005: ALN 15.252 ? Abandoned Mine Land Reclamation A Material Weakness and Material Noncompliance Exist at the Department of Environmental Protection Related to Subrecipient Monitoring (A Similar Condition Was Noted in Prior Year Finding 2021-004) Federal Grant Number(s) and Year(s): S21AF10015 (01/01/2021 ? 12/31/2023), S20AF20092 (10/01/2020 ? 09/30/2023), S20AF20006 (01/01/2020 ?? 12/31/2022), S19AF20006 (01/01/2019 ? 12/31/2021), S19AF20004 (12/01/2018 ? 11/30/2022), S18AF20004 (11/01/2017 ?10/31/2023) Type of Finding: Material Weakness, Material Noncompliance Compliance Requirement: Subrecipient Monitoring Condition: The Department of Environmental Protection (DEP) administers the Abandoned Mine Land Reclamation (AMLR) program funded by the United States Department of the Interior (DOI). During the fiscal year ended June 30, 2022, DEP expended $49,400,302 within the AMLR program, of which $13,270,381 was paid to 18 subrecipients with whom DEP executed subrecipient agreements to provide abandoned mine land reclamation repairs and services throughout Pennsylvania. Our audit testing disclosed that DEP did not conduct risk assessments or program monitoring of these subrecipient expenditures during the fiscal year ended June 30, 2022, since DEP considered these entities to be contractors and not subrecipients. Based on a recent determination made by DEP, these entities should be categorized as subrecipients. As such, DEP began implementing procedures to ensure federal regulations are met regarding subrecipient agreements. However, these procedures were implemented subsequent to the fiscal year ended June 30, 2022. While Single Audits of the AMLR subrecipients may be conducted each year, this auditing activity does not compensate for the lack of during-the-award program monitoring, since the timing, focus, and scope of subrecipient auditing activities after year end are different than compliance monitoring to be performed by program officials during the year. Criteria: As part of administering the AMLR program, DEP must have policies, procedures, and controls in place to ensure compliance with federal requirements within contract requirements and regulations. 2 CFR Section 200.332, Requirements for pass through entities, states in part: All pass-through entities must: (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 [Management decision]. Finding 2022 ? 005: (continued) (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425 [Audit services]. The standard contract agreement between DEP and the local grantee states, in part: Audit/Compliance Review Requirements - The contractor must comply with all applicable federal and state grant requirements including the Single Audit Act Amendments of 1996; 2 CFR Part 200 as amended; and any other applicable law or regulation, and any amendment to such other applicable law or regulation that may be enacted or promulgated by the federal government. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: In previous years, DEP management considered these entities as contractors for whom subrecipient monitoring requirements were not applicable. However, based on recent determinations, DEP acknowledges these entities as subrecipients, not contractors, subject to federal subrecipient requirements. Effect: Without the completion of risk assessments and subrecipient monitoring, DEP cannot ensure compliance with federal statutes, regulations, and the terms and conditions of the subrecipient contracts, confirm that local subrecipients are performing satisfactory work, ensure the efficient use of program resources, and minimize the risk for fraud and abuse. Completing monitoring activities is essential for DEP to determine whether the local agencies are complying with federal regulations and spending grant funds appropriately. Recommendation: We recommend that DEP continue to develop and implement written policies and procedures for performing risk based during-the-award subrecipient monitoring and implement them immediately to ensure timely subrecipient compliance with federal regulations. On-site monitoring visits by state officials should be supported by documentation to show the monitoring performed, areas examined, conclusions reached, and that the monitoring was performed in compliance with applicable regulations. Agency Response: The Department of Environmental Protection agrees with the facts as presented in this finding. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Department of Human Services Finding 2022 ? 008: ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2021-007) Federal Grant Number(s) and Year(s): 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 1801PATANF (10/01/2017 ? 9/30/2018), 1701PATANF (10/01/2016 ? 9/30/2017) Type of Finding: Significant Deficiency, Noncompliance Compliance Requirement: Subrecipient Monitoring Condition: During the fiscal year ended June 30, 2022, the Department of Human Services (DHS) paid $79.5 million in Temporary Assistance for Needy Families (TANF) funding to subrecipients within the New Directions, Cash Grants, and Alternatives to Abortion appropriations (or 22.1 percent) out of total federal TANF expenditures of $360.2 million reported on the June 30, 2022 Schedule of Expenditures of Federal Awards. Our testing of DHS?s during-the-award monitoring of subrecipients for the fiscal year ended June 30, 2022 disclosed that DHS performed on-site monitoring for 20 out of 21 subrecipients selected for testing. The on-site monitoring that was performed consisted of reviews of program operations including design, data entry accuracy and timeliness, case management analysis, and program payment performance goals. The on-site monitoring also included a review of a sample of TANF recipient case files to ensure that the recipients? TANF activities were documented and accurately entered in the Commonwealth?s Workforce Development System. However, DHS?s monitoring procedures for the 20 subrecipients were not adequate as they did not include a review or monitoring of subrecipient financial records, which would provide an assessment of a subrecipient?s compliance with applicable federal regulations. Although DHS?s monitoring procedures include reviewing subrecipient completed questionnaires for selected subrecipients that had questions related to financial matters, DHS?s monitoring personnel did not review subrecipient financial records. For example, DHS did not perform procedures to ensure subrecipient invoices agreed to the books and records of the subrecipient and that the records were adequate to support the allowability of costs paid by DHS during the award period. In addition, DHS?s monitoring procedures did not include an evaluation of the operating effectiveness of DHS subrecipients? procedures to monitor Single Audits and any related findings. Our testing of the 21 subrecipients noted above included follow up on one subrecipient identified in the prior year finding as not being on-site monitored by DHS when the risk assessment warranted on-site monitoring. Our follow-up during the current audit period disclosed that DHS did not conduct on-site monitoring for this subrecipient during the fiscal year ended June 30, 2022. Since the on-site monitoring was not completed, internal control weaknesses, noncompliance, and questioned costs may have existed and remained undetected during the current audit period. This subrecipient received $980,923 of TANF funds during the fiscal year ended June 30, 2022. Criteria: 45 CFR Section 75.352, Requirements for pass-through entities, states: All pass-through entities must: (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. Finding 2022 ? 008: (continued) (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 75.521 [Management decision]. 2 CFR Section 200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425 [Audit services]. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: DHS planned to implement new during-the-award monitoring procedures to be used for the on-site monitoring of subrecipients, but these procedures were not in place for monitoring conducted during the fiscal year ended June 30, 2022. Therefore, DHS has not implemented adequate during-the-award monitoring procedures of subrecipients to include testing of the financial records and the subrecipients? monitoring of Single Audits sufficient to ensure compliance with federal regulations. Regarding the one subrecipient for which on-site monitoring was not completed, DHS personnel stated that they are working with the subrecipient to obtain the necessary documentation to complete the on-site monitoring. Effect: TANF subrecipients could be operating in noncompliance with federal regulations without timely detection and correction by DHS management. Recommendation: DHS should strengthen its controls to ensure during-the-award monitoring of TANF subrecipients includes procedures to ensure that subrecipients are in compliance with applicable federal regulations. This should include examining subrecipients? financial records and ensuring that all required Single Audits were obtained by DHS subrecipients. Agency Response: DHS agrees with this finding. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Department of Human Services Finding 2022 ? 008: ALN 93.558 ? Temporary Assistance for Needy Families (including COVID-19) Department of Human Services Did Not Validate Financial Information as Part of Its On-Site Monitoring of Temporary Assistance for Needy Families Subrecipients (A Similar Condition Was Noted in Prior Year Finding 2021-007) Federal Grant Number(s) and Year(s): 2201PATANF (10/01/2021 ? 9/30/2022), 2101PATANF (10/01/2020 ? 9/30/2021), 2001PATANF (10/01/2019 ? 9/30/2020), 1801PATANF (10/01/2017 ? 9/30/2018), 1701PATANF (10/01/2016 ? 9/30/2017) Type of Finding: Significant Deficiency, Noncompliance Compliance Requirement: Subrecipient Monitoring Condition: During the fiscal year ended June 30, 2022, the Department of Human Services (DHS) paid $79.5 million in Temporary Assistance for Needy Families (TANF) funding to subrecipients within the New Directions, Cash Grants, and Alternatives to Abortion appropriations (or 22.1 percent) out of total federal TANF expenditures of $360.2 million reported on the June 30, 2022 Schedule of Expenditures of Federal Awards. Our testing of DHS?s during-the-award monitoring of subrecipients for the fiscal year ended June 30, 2022 disclosed that DHS performed on-site monitoring for 20 out of 21 subrecipients selected for testing. The on-site monitoring that was performed consisted of reviews of program operations including design, data entry accuracy and timeliness, case management analysis, and program payment performance goals. The on-site monitoring also included a review of a sample of TANF recipient case files to ensure that the recipients? TANF activities were documented and accurately entered in the Commonwealth?s Workforce Development System. However, DHS?s monitoring procedures for the 20 subrecipients were not adequate as they did not include a review or monitoring of subrecipient financial records, which would provide an assessment of a subrecipient?s compliance with applicable federal regulations. Although DHS?s monitoring procedures include reviewing subrecipient completed questionnaires for selected subrecipients that had questions related to financial matters, DHS?s monitoring personnel did not review subrecipient financial records. For example, DHS did not perform procedures to ensure subrecipient invoices agreed to the books and records of the subrecipient and that the records were adequate to support the allowability of costs paid by DHS during the award period. In addition, DHS?s monitoring procedures did not include an evaluation of the operating effectiveness of DHS subrecipients? procedures to monitor Single Audits and any related findings. Our testing of the 21 subrecipients noted above included follow up on one subrecipient identified in the prior year finding as not being on-site monitored by DHS when the risk assessment warranted on-site monitoring. Our follow-up during the current audit period disclosed that DHS did not conduct on-site monitoring for this subrecipient during the fiscal year ended June 30, 2022. Since the on-site monitoring was not completed, internal control weaknesses, noncompliance, and questioned costs may have existed and remained undetected during the current audit period. This subrecipient received $980,923 of TANF funds during the fiscal year ended June 30, 2022. Criteria: 45 CFR Section 75.352, Requirements for pass-through entities, states: All pass-through entities must: (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. Finding 2022 ? 008: (continued) (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 75.521 [Management decision]. 2 CFR Section 200.332, Requirements for pass-through entities, states in part: All pass-through entities must: (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in ?200.425 [Audit services]. Management Directive 325.12, Amended ? Standards for Enterprise Risk Management in Commonwealth Agencies, adopted the internal control framework outlined in the United States Government Accountability Office?s Standards for Internal Control in the Federal Government (Green Book). The Green Book states in part: Management should establish and operate monitoring activities to monitor the internal control system and evaluate the results. Management should remediate identified internal control deficiencies on a timely basis. Cause: DHS planned to implement new during-the-award monitoring procedures to be used for the on-site monitoring of subrecipients, but these procedures were not in place for monitoring conducted during the fiscal year ended June 30, 2022. Therefore, DHS has not implemented adequate during-the-award monitoring procedures of subrecipients to include testing of the financial records and the subrecipients? monitoring of Single Audits sufficient to ensure compliance with federal regulations. Regarding the one subrecipient for which on-site monitoring was not completed, DHS personnel stated that they are working with the subrecipient to obtain the necessary documentation to complete the on-site monitoring. Effect: TANF subrecipients could be operating in noncompliance with federal regulations without timely detection and correction by DHS management. Recommendation: DHS should strengthen its controls to ensure during-the-award monitoring of TANF subrecipients includes procedures to ensure that subrecipients are in compliance with applicable federal regulations. This should include examining subrecipients? financial records and ensuring that all required Single Audits were obtained by DHS subrecipients. Agency Response: DHS agrees with this finding. Questioned Costs: The amount of questioned costs cannot be determined. The corrective action plan for this finding, if any, has not been reviewed by the auditors. See Corrective Action Plans located elsewhere in this Report.
Reference Number: 2022-023 Prior Year Finding: 2021-018 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Opioid STR Assistance Listing Number: 93.788 Award Number and Year: H79TI083305 (9/30/2020 ? 9/29/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (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 in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it monitored its subrecipients. Context: For 4 of 8 subrecipients selected for testing, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Recommendation: The Division should review and enhance internal controls and procedures to ensure that proper subrecipient monitoring is conducted in accordance with Federal regulations. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (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 in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it furnished required information to its subrecipients at the time of subaward, monitored its subrecipients, or ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in four of eight subrecipients selected for testing (exceptions listed include multiple exceptions for some subrecipients): ? Four of eight subrecipient agreements were missing the following required information: Subrecipient?s Unique Identifier, Federal Award Identification Number (FAIN), Federal Award Date, Federal Award Project Description, Assistance Listing Number and Title. ? For one of eight subrecipients, the Division was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The Division could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. ? For four of eight subrecipients, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, also that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Reference Number: 2022-024 Prior Year Finding: 2021-024 Federal Agency: U.S. Department of Health and Human Services State Department Name: Department of Health and Social Services State Division Name: Division of Substance Abuse and Mental Health Federal Program: Block Grants for Prevention and Treatment of Substance Abuse, COVID-10 - Block Grants for Prevention and Treatment of Substance Abuse Assistance Listing Number: 93.959 Award Number and Year: B08TI083060 (10/1/2019 ? 9/30/2021), B08TI083488 (10/1/2020 ? 9/30/2022) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (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 in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521 Management decision. (e) Depending upon the pass-through entity?s assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient?s program operations; (3) Arranging for agreed-upon-procedures engagements as described in ? 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The Division was not able to provide support that it furnished required information to its subrecipients at the time of subaward, monitored its subrecipients, or ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in four of eight subrecipients selected for testing (exceptions listed include multiple exceptions for some subrecipients): ? Four of eight subrecipient agreements were missing the following required information: Subrecipient?s Unique Identifier, Federal Award Identification Number (FAIN), Federal Award Date, Federal Award Project Description, Assistance Listing Number and Title. ? For one of eight subrecipients, the Division was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The Division could not produce evidence of verification that the subrecipient?s Federal awards expended during the fiscal year were below the threshold set forth in ? 200.501 Audit requirements. ? For four of eight subrecipients, the Division was unable to provide support that it conducted during the award monitoring as required by the Division?s policies and procedures. Questioned costs: Undetermined. Cause: The Division did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Excluding the required federal grant award information at the time of the subaward may cause subrecipients and their auditors to be uninformed about specific program and other regulations that apply to the funds they receive. There is also the potential for subrecipients to have incomplete Schedules of Expenditures of Federal Awards (SEFA) in their Single Audit reports, and federal funds may not be properly audited at the subrecipient level in accordance with the Uniform Guidance. Not conducting during the award monitoring may result in a failure of the Division to detect that its subrecipients used subawards for unauthorized purposes, managed them in violation of the terms and conditions of the subawards, or that subaward performance goals were not achieved. Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, and corrected by Division personnel on a timely basis. Recommendation: The Division should review and enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Division has been working to implement corrective action, as this was a prior finding. The implementation timeline overlapped into the current audit period. DSAMH continues to reevaluate its current process and to enhance internal controls and procedures to ensure that all required information is included in all subawards and provided to the subrecipients, also that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed.
Finding Number: 2021-002; Finding Type: Federal award finding and financial statement finding; Federal Assistance Listing No.: 1) 16.556 2) 93.591; Program Names: 1) State Domestic Violence and Sexual Assault Coalitions 2) Family Violence Prevention and Services/State Domestic Violence Coalition; Federal Agencies: 1) U.S. Department of Justice 2) U.S. Department of Health and Human Services; Pass-Through Entity: n/a; Grant Numbers: 1) 2019-MU-AX-0017, 2) 2001ORSDC3; Federal Award Year: 2021; Control Deficiency Type: Material weakness in internal controls over compliance and financial reporting Instance of Noncompliance: Yes; Compliance Requirement: Allowable costs; Questioned Costs: 1) ALN 16.556: none over $25,000 2) ALN 93.591: $53,351; Repeat Finding: No; Criteria: According to 2 CFR §200.405, costs of a federal award must be allowable and allocable. A cost is allocable to a particular federal award if the goods or services involved are chargeable to the federal award in accordance with relative benefits received. This standard is met if the cost was incurred specifically for the federal award; benefits both the federal award and other work of the non-federal entity and can be distributed in proportions that may be approximated using reasonable methods; and is necessary to the overall operation of the non-federal entity and is assignable in part to the federal award in accordance with cost principles in this section. An organization must use an equitable distribution base to allocate its indirect and administrative costs. The organization should have controls in place to ensure that indirect costs are charged uniformly to both federally funded activities and other activities of the organization, and the allocation methodology results in an equitable allocation of indirect and shared administrative costs. Condition: During the audit, it was noted that costs appearing administrative in nature were charged as direct costs to two federal awards, including $39,814 of the accounting manager’s salary and $26,797 in audit fees relating to the fiscal year 2020 audit, a year in which no Single Audit was require or performed. In accordance with CFR §200.425, costs of auditing a non-federal entity that is exempted from having an audit conducted under the Single Audit Act because its expenditures under federal awards are less than $750,000 during the non-federal entity’s fiscal year are considered unallowable costs. Cause: The organization did not have a proper understanding of the Uniform Guidance regulations governing the expenditure of federal funds. Effect: Costs that appeared to be administrative in nature and benefitted all programs were charged to two federal grants as direct expenses: $53,351 to ALN 93.591 and $13,260 to ALN 16.556. Audit Recommendation: We recommend the Coalition develop controls and procedures to correctly distinguish between direct and indirect costs, as well as, procedures to identify and exclude costs that the Uniform Guidance has indicated as unallowable costs. Management’s Response: OCADSV added an Administrative Cost Center to its General Ledger effective 10/01/22, the beginning of FY23 and began costing administrative payroll cost to that cost center. Additionally, the organization retrained administrative staff on direct cost allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. Audit costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23 all accounting and other admin payroll related cost will be allocated to the administration cost center with the exception of time spent in activities related to a specific grant or other cost center. FY22 grant expenditures were reviewed post year-end and a line-by-line review was conducted to bring the di-rect and indirect expense cumulative total into compliance with audit findings. Any outstanding reports were adjusted to reflect the adjusted Life of Grant to current date reporting. Executive, Financial and Grant Management staff will, during FY24, complete the Online Grants Financial Management Training available at onlinegfmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200 guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired employee who have direct responsibilities related to grant management and/or reporting
Finding Number: 2021-002; Finding Type: Federal award finding and financial statement finding; Federal Assistance Listing No.: 1) 16.556 2) 93.591; Program Names: 1) State Domestic Violence and Sexual Assault Coalitions 2) Family Violence Prevention and Services/State Domestic Violence Coalition; Federal Agencies: 1) U.S. Department of Justice 2) U.S. Department of Health and Human Services; Pass-Through Entity: n/a; Grant Numbers: 1) 2019-MU-AX-0017, 2) 2001ORSDC3; Federal Award Year: 2021; Control Deficiency Type: Material weakness in internal controls over compliance and financial reporting Instance of Noncompliance: Yes; Compliance Requirement: Allowable costs; Questioned Costs: 1) ALN 16.556: none over $25,000 2) ALN 93.591: $53,351; Repeat Finding: No; Criteria: According to 2 CFR §200.405, costs of a federal award must be allowable and allocable. A cost is allocable to a particular federal award if the goods or services involved are chargeable to the federal award in accordance with relative benefits received. This standard is met if the cost was incurred specifically for the federal award; benefits both the federal award and other work of the non-federal entity and can be distributed in proportions that may be approximated using reasonable methods; and is necessary to the overall operation of the non-federal entity and is assignable in part to the federal award in accordance with cost principles in this section. An organization must use an equitable distribution base to allocate its indirect and administrative costs. The organization should have controls in place to ensure that indirect costs are charged uniformly to both federally funded activities and other activities of the organization, and the allocation methodology results in an equitable allocation of indirect and shared administrative costs. Condition: During the audit, it was noted that costs appearing administrative in nature were charged as direct costs to two federal awards, including $39,814 of the accounting manager’s salary and $26,797 in audit fees relating to the fiscal year 2020 audit, a year in which no Single Audit was require or performed. In accordance with CFR §200.425, costs of auditing a non-federal entity that is exempted from having an audit conducted under the Single Audit Act because its expenditures under federal awards are less than $750,000 during the non-federal entity’s fiscal year are considered unallowable costs. Cause: The organization did not have a proper understanding of the Uniform Guidance regulations governing the expenditure of federal funds. Effect: Costs that appeared to be administrative in nature and benefitted all programs were charged to two federal grants as direct expenses: $53,351 to ALN 93.591 and $13,260 to ALN 16.556. Audit Recommendation: We recommend the Coalition develop controls and procedures to correctly distinguish between direct and indirect costs, as well as, procedures to identify and exclude costs that the Uniform Guidance has indicated as unallowable costs. Management’s Response: OCADSV added an Administrative Cost Center to its General Ledger effective 10/01/22, the beginning of FY23 and began costing administrative payroll cost to that cost center. Additionally, the organization retrained administrative staff on direct cost allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. Audit costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23 all accounting and other admin payroll related cost will be allocated to the administration cost center with the exception of time spent in activities related to a specific grant or other cost center. FY22 grant expenditures were reviewed post year-end and a line-by-line review was conducted to bring the di-rect and indirect expense cumulative total into compliance with audit findings. Any outstanding reports were adjusted to reflect the adjusted Life of Grant to current date reporting. Executive, Financial and Grant Management staff will, during FY24, complete the Online Grants Financial Management Training available at onlinegfmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200 guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired employee who have direct responsibilities related to grant management and/or reporting
Finding Number: 2021-002; Finding Type: Federal award finding and financial statement finding; Federal Assistance Listing No.: 1) 16.556 2) 93.591; Program Names: 1) State Domestic Violence and Sexual Assault Coalitions 2) Family Violence Prevention and Services/State Domestic Violence Coalition; Federal Agencies: 1) U.S. Department of Justice 2) U.S. Department of Health and Human Services; Pass-Through Entity: n/a; Grant Numbers: 1) 2019-MU-AX-0017, 2) 2001ORSDC3; Federal Award Year: 2021; Control Deficiency Type: Material weakness in internal controls over compliance and financial reporting Instance of Noncompliance: Yes; Compliance Requirement: Allowable costs; Questioned Costs: 1) ALN 16.556: none over $25,000 2) ALN 93.591: $53,351; Repeat Finding: No; Criteria: According to 2 CFR §200.405, costs of a federal award must be allowable and allocable. A cost is allocable to a particular federal award if the goods or services involved are chargeable to the federal award in accordance with relative benefits received. This standard is met if the cost was incurred specifically for the federal award; benefits both the federal award and other work of the non-federal entity and can be distributed in proportions that may be approximated using reasonable methods; and is necessary to the overall operation of the non-federal entity and is assignable in part to the federal award in accordance with cost principles in this section. An organization must use an equitable distribution base to allocate its indirect and administrative costs. The organization should have controls in place to ensure that indirect costs are charged uniformly to both federally funded activities and other activities of the organization, and the allocation methodology results in an equitable allocation of indirect and shared administrative costs. Condition: During the audit, it was noted that costs appearing administrative in nature were charged as direct costs to two federal awards, including $39,814 of the accounting manager’s salary and $26,797 in audit fees relating to the fiscal year 2020 audit, a year in which no Single Audit was require or performed. In accordance with CFR §200.425, costs of auditing a non-federal entity that is exempted from having an audit conducted under the Single Audit Act because its expenditures under federal awards are less than $750,000 during the non-federal entity’s fiscal year are considered unallowable costs. Cause: The organization did not have a proper understanding of the Uniform Guidance regulations governing the expenditure of federal funds. Effect: Costs that appeared to be administrative in nature and benefitted all programs were charged to two federal grants as direct expenses: $53,351 to ALN 93.591 and $13,260 to ALN 16.556. Audit Recommendation: We recommend the Coalition develop controls and procedures to correctly distinguish between direct and indirect costs, as well as, procedures to identify and exclude costs that the Uniform Guidance has indicated as unallowable costs. Management’s Response: OCADSV added an Administrative Cost Center to its General Ledger effective 10/01/22, the beginning of FY23 and began costing administrative payroll cost to that cost center. Additionally, the organization retrained administrative staff on direct cost allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. Audit costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23 all accounting and other admin payroll related cost will be allocated to the administration cost center with the exception of time spent in activities related to a specific grant or other cost center. FY22 grant expenditures were reviewed post year-end and a line-by-line review was conducted to bring the di-rect and indirect expense cumulative total into compliance with audit findings. Any outstanding reports were adjusted to reflect the adjusted Life of Grant to current date reporting. Executive, Financial and Grant Management staff will, during FY24, complete the Online Grants Financial Management Training available at onlinegfmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200 guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired employee who have direct responsibilities related to grant management and/or reporting
Finding Number: 2021-002; Finding Type: Federal award finding and financial statement finding; Federal Assistance Listing No.: 1) 16.556 2) 93.591; Program Names: 1) State Domestic Violence and Sexual Assault Coalitions 2) Family Violence Prevention and Services/State Domestic Violence Coalition; Federal Agencies: 1) U.S. Department of Justice 2) U.S. Department of Health and Human Services; Pass-Through Entity: n/a; Grant Numbers: 1) 2019-MU-AX-0017, 2) 2001ORSDC3; Federal Award Year: 2021; Control Deficiency Type: Material weakness in internal controls over compliance and financial reporting Instance of Noncompliance: Yes; Compliance Requirement: Allowable costs; Questioned Costs: 1) ALN 16.556: none over $25,000 2) ALN 93.591: $53,351; Repeat Finding: No; Criteria: According to 2 CFR §200.405, costs of a federal award must be allowable and allocable. A cost is allocable to a particular federal award if the goods or services involved are chargeable to the federal award in accordance with relative benefits received. This standard is met if the cost was incurred specifically for the federal award; benefits both the federal award and other work of the non-federal entity and can be distributed in proportions that may be approximated using reasonable methods; and is necessary to the overall operation of the non-federal entity and is assignable in part to the federal award in accordance with cost principles in this section. An organization must use an equitable distribution base to allocate its indirect and administrative costs. The organization should have controls in place to ensure that indirect costs are charged uniformly to both federally funded activities and other activities of the organization, and the allocation methodology results in an equitable allocation of indirect and shared administrative costs. Condition: During the audit, it was noted that costs appearing administrative in nature were charged as direct costs to two federal awards, including $39,814 of the accounting manager’s salary and $26,797 in audit fees relating to the fiscal year 2020 audit, a year in which no Single Audit was require or performed. In accordance with CFR §200.425, costs of auditing a non-federal entity that is exempted from having an audit conducted under the Single Audit Act because its expenditures under federal awards are less than $750,000 during the non-federal entity’s fiscal year are considered unallowable costs. Cause: The organization did not have a proper understanding of the Uniform Guidance regulations governing the expenditure of federal funds. Effect: Costs that appeared to be administrative in nature and benefitted all programs were charged to two federal grants as direct expenses: $53,351 to ALN 93.591 and $13,260 to ALN 16.556. Audit Recommendation: We recommend the Coalition develop controls and procedures to correctly distinguish between direct and indirect costs, as well as, procedures to identify and exclude costs that the Uniform Guidance has indicated as unallowable costs. Management’s Response: OCADSV added an Administrative Cost Center to its General Ledger effective 10/01/22, the beginning of FY23 and began costing administrative payroll cost to that cost center. Additionally, the organization retrained administrative staff on direct cost allowable activities vs. administrative activities relative to timekeeping and timesheet preparation and the necessity of daily work descriptions supporting the hourly allocation. The Payroll policy that requires supervisors to review and sign off on timesheets and hourly allocations to cost centers was also reviewed. Audit costs for FY22 will be allocated in accordance with 2 CFR 200.405 requirements. Beginning with FY23 all accounting and other admin payroll related cost will be allocated to the administration cost center with the exception of time spent in activities related to a specific grant or other cost center. FY22 grant expenditures were reviewed post year-end and a line-by-line review was conducted to bring the di-rect and indirect expense cumulative total into compliance with audit findings. Any outstanding reports were adjusted to reflect the adjusted Life of Grant to current date reporting. Executive, Financial and Grant Management staff will, during FY24, complete the Online Grants Financial Management Training available at onlinegfmt.training.ojp.gov to improve knowledge and compliance with 2 CFR 200 guidance and requirements. The said training will be incorporated into onboarding processes for any newly hired employee who have direct responsibilities related to grant management and/or reporting