U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o 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 PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 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. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-017 NH Department of Health and Human Services Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) and COVID-19 Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) Federal Award Numbers: 1B08Ti084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $7,720,172 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. The Department provided the most recent risk assessment performed for each of the 7 subrecipients selected for testwork. Per review of the risk assessments provided, we identified the following: 1. For 5 of the subrecipients, the risk assessment indicated that the subrecipients expenditure detail should be examined monthly to ensure compliance with contract requirements and applicable laws and rules. We were unable to determine if this procedure had been performed as part of the Department’s subrecipient monitoring process. 2. For the remaining 2 subrecipients the recommended monitoring procedures was left blank on the risk assessment and as such we are unable to verify what type of monitoring procedures should have been performed. B. The Department’s during the award monitoring for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified that for 2 of 7 subrecipients selected for testwork, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department review its existing policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials Management partially concurs with the finding above. Rejoinder As it relates to Bullet A above, we were not able to obtain documentation to support that the suggested procedures outlined within the risk assessment was performed. As it relates to Bullet B above, for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement.
Finding Reference Number: 2023-017 NH Department of Health and Human Services Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) and COVID-19 Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) Federal Award Numbers: 1B08Ti084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $7,720,172 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. The Department provided the most recent risk assessment performed for each of the 7 subrecipients selected for testwork. Per review of the risk assessments provided, we identified the following: 1. For 5 of the subrecipients, the risk assessment indicated that the subrecipients expenditure detail should be examined monthly to ensure compliance with contract requirements and applicable laws and rules. We were unable to determine if this procedure had been performed as part of the Department’s subrecipient monitoring process. 2. For the remaining 2 subrecipients the recommended monitoring procedures was left blank on the risk assessment and as such we are unable to verify what type of monitoring procedures should have been performed. B. The Department’s during the award monitoring for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified that for 2 of 7 subrecipients selected for testwork, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department review its existing policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials Management partially concurs with the finding above. Rejoinder As it relates to Bullet A above, we were not able to obtain documentation to support that the suggested procedures outlined within the risk assessment was performed. As it relates to Bullet B above, for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement.
Finding Reference Number: 2023-023 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2023, $27,041,873 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 27 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: - Subrecipient unique entity identifier (not communicated for 19/27); - Federal Award Identification Number (FAIN) (not communicated for 27/27); - Identification of whether the award is R&D (not communicated for 27/27); and - Indirect cost rate for the federal award (including if the de minimis rate is charged) (not communicated for 27/27) B. The Department evaluated the subrecipient risk of noncompliance through a risk assessment for each of the 13 subrecipients selected for testwork. However, there was no formal risk assessment policy in place that indicated how frequently risk assessments should be performed. As a result, 5 subrecipients did not have risk assessments performed during the current year for purposes of determining the appropriate subrecipient monitoring response. These prior fiscal year(s) risk assessments were performed as of the following dates: September 2019, October and December 2021, May and June 2022. C. For each of the 13 subrecipients selected for testwork, the Department did not perform any during the award monitoring. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no UG report review policies and procedures in place. For the 13 subrecipients selected for testwork, 6 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 5 of 13 subrecipients, the subrecipient’s uniform guidance was not reviewed due to updated risk assessments not being performed in the current year (refer to item 2 above) • For 1 of 13 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report Cause The cause of the condition found was primarily due to the Department not performing their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-023 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2023, $27,041,873 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 27 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: - Subrecipient unique entity identifier (not communicated for 19/27); - Federal Award Identification Number (FAIN) (not communicated for 27/27); - Identification of whether the award is R&D (not communicated for 27/27); and - Indirect cost rate for the federal award (including if the de minimis rate is charged) (not communicated for 27/27) B. The Department evaluated the subrecipient risk of noncompliance through a risk assessment for each of the 13 subrecipients selected for testwork. However, there was no formal risk assessment policy in place that indicated how frequently risk assessments should be performed. As a result, 5 subrecipients did not have risk assessments performed during the current year for purposes of determining the appropriate subrecipient monitoring response. These prior fiscal year(s) risk assessments were performed as of the following dates: September 2019, October and December 2021, May and June 2022. C. For each of the 13 subrecipients selected for testwork, the Department did not perform any during the award monitoring. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no UG report review policies and procedures in place. For the 13 subrecipients selected for testwork, 6 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 5 of 13 subrecipients, the subrecipient’s uniform guidance was not reviewed due to updated risk assessments not being performed in the current year (refer to item 2 above) • For 1 of 13 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report Cause The cause of the condition found was primarily due to the Department not performing their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Passed-through: California Department of Transportation Award Number and Year: 5923, 2022/2023 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as 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. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient’s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County, no risk assessment was performed, and no subrecipient monitoring was performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. single audit in the period the expenditures were incurred. Cause: The County improperly identified the subrecipient as a contractor. The County did not perform an evaluation of the agreement to determine whether the vendor was a contractor or a subrecipient. Effect: The County did not comply with the subrecipient monitoring compliance requirements. Questioned Costs: None reported. Context/Sampling: We selected 100% of the County’s subrecipients of the program. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the County establish procedures to determine whether agreements represent a contractor or a subrecipient arrangement. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
New York City Department for the Aging (“DFTA”) Finding #: 2023-010 Funding Year(s): 07/01/2022 - 06/30/2023 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated in 2 CFR 200.332(f) pass-through entities should verify that every subrecipient that expends $750,000 or more in federal awards during their fiscal year has a single or program-specific audit conducted for that fiscal year in accordance with 2 CFR 200.501. Additionally, per 2 CFR 200.512(a)(1) the audit must be completed and the data collection form along with the reporting package must be submitted to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Condition/Context: Of the forty (40) subrecipients under the Aging Cluster that were selected for testing, four (4) of the single audit report dates were beyond the nine-month required submission date required by 2 CFR 200.512(a)(1). For these four (4) selections, DFTA was unable to provide supporting documentation of notification by the subrecipient of the late submission and acknowledgment of the notification by DFTA. Cause/Effect: While DFTA has established subrecipient monitoring procedures, we noted that monitoring of subrecipient compliance with federal statues, regulations and terms and conditions of the federal award were not consistently performed and documented. Missing or incomplete monitoring procedures could result in subrecipients not complying with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements stipulated by 2 CFR 200.332 are being met, including following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient detected through audits, on-site reviews, and written confirmation from the subrecipient.
New York City Department for the Aging (“DFTA”) Finding #: 2023-010 Funding Year(s): 07/01/2022 - 06/30/2023 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated in 2 CFR 200.332(f) pass-through entities should verify that every subrecipient that expends $750,000 or more in federal awards during their fiscal year has a single or program-specific audit conducted for that fiscal year in accordance with 2 CFR 200.501. Additionally, per 2 CFR 200.512(a)(1) the audit must be completed and the data collection form along with the reporting package must be submitted to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Condition/Context: Of the forty (40) subrecipients under the Aging Cluster that were selected for testing, four (4) of the single audit report dates were beyond the nine-month required submission date required by 2 CFR 200.512(a)(1). For these four (4) selections, DFTA was unable to provide supporting documentation of notification by the subrecipient of the late submission and acknowledgment of the notification by DFTA. Cause/Effect: While DFTA has established subrecipient monitoring procedures, we noted that monitoring of subrecipient compliance with federal statues, regulations and terms and conditions of the federal award were not consistently performed and documented. Missing or incomplete monitoring procedures could result in subrecipients not complying with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements stipulated by 2 CFR 200.332 are being met, including following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient detected through audits, on-site reviews, and written confirmation from the subrecipient.
New York City Department for the Aging (“DFTA”) Finding #: 2023-010 Funding Year(s): 07/01/2022 - 06/30/2023 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated in 2 CFR 200.332(f) pass-through entities should verify that every subrecipient that expends $750,000 or more in federal awards during their fiscal year has a single or program-specific audit conducted for that fiscal year in accordance with 2 CFR 200.501. Additionally, per 2 CFR 200.512(a)(1) the audit must be completed and the data collection form along with the reporting package must be submitted to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Condition/Context: Of the forty (40) subrecipients under the Aging Cluster that were selected for testing, four (4) of the single audit report dates were beyond the nine-month required submission date required by 2 CFR 200.512(a)(1). For these four (4) selections, DFTA was unable to provide supporting documentation of notification by the subrecipient of the late submission and acknowledgment of the notification by DFTA. Cause/Effect: While DFTA has established subrecipient monitoring procedures, we noted that monitoring of subrecipient compliance with federal statues, regulations and terms and conditions of the federal award were not consistently performed and documented. Missing or incomplete monitoring procedures could result in subrecipients not complying with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements stipulated by 2 CFR 200.332 are being met, including following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient detected through audits, on-site reviews, and written confirmation from the subrecipient.
New York City Department for the Aging (“DFTA”) Finding #: 2023-010 Funding Year(s): 07/01/2022 - 06/30/2023 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated in 2 CFR 200.332(f) pass-through entities should verify that every subrecipient that expends $750,000 or more in federal awards during their fiscal year has a single or program-specific audit conducted for that fiscal year in accordance with 2 CFR 200.501. Additionally, per 2 CFR 200.512(a)(1) the audit must be completed and the data collection form along with the reporting package must be submitted to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Condition/Context: Of the forty (40) subrecipients under the Aging Cluster that were selected for testing, four (4) of the single audit report dates were beyond the nine-month required submission date required by 2 CFR 200.512(a)(1). For these four (4) selections, DFTA was unable to provide supporting documentation of notification by the subrecipient of the late submission and acknowledgment of the notification by DFTA. Cause/Effect: While DFTA has established subrecipient monitoring procedures, we noted that monitoring of subrecipient compliance with federal statues, regulations and terms and conditions of the federal award were not consistently performed and documented. Missing or incomplete monitoring procedures could result in subrecipients not complying with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements stipulated by 2 CFR 200.332 are being met, including following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient detected through audits, on-site reviews, and written confirmation from the subrecipient.
New York City Department for the Aging (“DFTA”) Finding #: 2023-010 Funding Year(s): 07/01/2022 - 06/30/2023 New York City Department for the Aging: Aging Cluster (FAL #93.044, 93.045 & 93.053) Contract Number: N/A Pass-Through Agency: New York State Office for the Aging Type of Finding: Subrecipient Monitoring Compliance and Internal Control (Significant Deficiency) Criteria: As stipulated in 2 CFR 200.332(f) pass-through entities should verify that every subrecipient that expends $750,000 or more in federal awards during their fiscal year has a single or program-specific audit conducted for that fiscal year in accordance with 2 CFR 200.501. Additionally, per 2 CFR 200.512(a)(1) the audit must be completed and the data collection form along with the reporting package must be submitted to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Condition/Context: Of the forty (40) subrecipients under the Aging Cluster that were selected for testing, four (4) of the single audit report dates were beyond the nine-month required submission date required by 2 CFR 200.512(a)(1). For these four (4) selections, DFTA was unable to provide supporting documentation of notification by the subrecipient of the late submission and acknowledgment of the notification by DFTA. Cause/Effect: While DFTA has established subrecipient monitoring procedures, we noted that monitoring of subrecipient compliance with federal statues, regulations and terms and conditions of the federal award were not consistently performed and documented. Missing or incomplete monitoring procedures could result in subrecipients not complying with Uniform Guidance reporting and/or other program specific compliance requirements. Questioned Costs: None identified. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend that DFTA create a comprehensive internal control structure which ensures that all subrecipient compliance requirements stipulated by 2 CFR 200.332 are being met, including following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient detected through audits, on-site reviews, and written confirmation from the subrecipient.
Reference Number: 2023-015 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Health Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525-02-03 (8/1/2020 - 7/31/2024), 5NU50CK000525-03-00 (8/1/2019 – 7/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must 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. 2 CFR section 200.332 also states that pass-through entities must: (d) 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). (e) 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. Section III – Federal Award Findings and Questioned Costs (Continued) (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. (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 be in compliance 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: Documentation of subaward agreements and monitoring activities was not maintained and was not available for audit. Context: The Department of Health (DOH) is the primary recipient of program funding and, therefore, has overall responsibility for activities funded by the program. DOH entered into an agreement with the Department of Education (DOE) to issue subawards to public and non-public schools on their behalf. Six of twenty-six subrecipients selected for testing received subawards issued by DOE. DOE was unable to provide copies of subaward agreements or documentation that subrecipient monitoring activities had been performed. Therefore, auditors were unable to verify compliance with Federal requirements for these subawards. Questioned costs: Undetermined. Cause: The agreement between DOH and DOE did not clearly state DOE’s responsibilities for subaward issuance and monitoring. As a result, DOE did not maintain copies of subaward agreements, nor was it able to provide documentation that it had performed risk assessments or monitoring activities for these subrecipients. In its oversight role, DOH did not review documentation maintained by DOE to ensure compliance with Federal subrecipient monitoring requirements. Effect: Auditors were unable to verify that subawards were issued in accordance with Federal requirements, that the subrecipients were eligible to receive program funding, nor that the subrecipients had been adequately monitored. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: DOH should review and enhance internal controls and procedures regarding agreements with other State departments to issue subawards on its behalf. Agreements should clearly define the responsibilities of other departments to ensure compliance with all Federal requirements. DOH should also periodically review the documentation maintained by other departments that issue subawards on its behalf to ensure it is adequate and is available for audit. DOE should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Documentation of subrecipient monitoring activities should be readily available for audit. Views of responsible officials: The Department of Health (DOH) will enhance its internal controls and procedures, regarding federal subawards issued by other New Jersey State departments and agencies on behalf of DOH. The Department’s Memorandum of Agreement (MOA) and Memorandum of Understanding (MOU) documents will be updated and enhanced to list and define the specific responsibilities and requirements of other departments and pass-through entities more clearly when issuing subawards with federal funding derived from DOH. If necessary, the updated MOA/MOU documents may also include an Exhibit specific to Subrecipient Monitoring, containing the federal Uniform Guidance compliance requirements including mandatory reporting of subgrantee performance indicators and listing records retention requirements for all documentation of monitored subrecipient activities.
Reference Number: 2023-015 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Health Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525-02-03 (8/1/2020 - 7/31/2024), 5NU50CK000525-03-00 (8/1/2019 – 7/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must 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. 2 CFR section 200.332 also states that pass-through entities must: (d) 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). (e) 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. Section III – Federal Award Findings and Questioned Costs (Continued) (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. (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 be in compliance 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: Documentation of subaward agreements and monitoring activities was not maintained and was not available for audit. Context: The Department of Health (DOH) is the primary recipient of program funding and, therefore, has overall responsibility for activities funded by the program. DOH entered into an agreement with the Department of Education (DOE) to issue subawards to public and non-public schools on their behalf. Six of twenty-six subrecipients selected for testing received subawards issued by DOE. DOE was unable to provide copies of subaward agreements or documentation that subrecipient monitoring activities had been performed. Therefore, auditors were unable to verify compliance with Federal requirements for these subawards. Questioned costs: Undetermined. Cause: The agreement between DOH and DOE did not clearly state DOE’s responsibilities for subaward issuance and monitoring. As a result, DOE did not maintain copies of subaward agreements, nor was it able to provide documentation that it had performed risk assessments or monitoring activities for these subrecipients. In its oversight role, DOH did not review documentation maintained by DOE to ensure compliance with Federal subrecipient monitoring requirements. Effect: Auditors were unable to verify that subawards were issued in accordance with Federal requirements, that the subrecipients were eligible to receive program funding, nor that the subrecipients had been adequately monitored. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: DOH should review and enhance internal controls and procedures regarding agreements with other State departments to issue subawards on its behalf. Agreements should clearly define the responsibilities of other departments to ensure compliance with all Federal requirements. DOH should also periodically review the documentation maintained by other departments that issue subawards on its behalf to ensure it is adequate and is available for audit. DOE should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Documentation of subrecipient monitoring activities should be readily available for audit. Views of responsible officials: The Department of Health (DOH) will enhance its internal controls and procedures, regarding federal subawards issued by other New Jersey State departments and agencies on behalf of DOH. The Department’s Memorandum of Agreement (MOA) and Memorandum of Understanding (MOU) documents will be updated and enhanced to list and define the specific responsibilities and requirements of other departments and pass-through entities more clearly when issuing subawards with federal funding derived from DOH. If necessary, the updated MOA/MOU documents may also include an Exhibit specific to Subrecipient Monitoring, containing the federal Uniform Guidance compliance requirements including mandatory reporting of subgrantee performance indicators and listing records retention requirements for all documentation of monitored subrecipient activities.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) 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. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (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. (f) 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. 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: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: • For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. • Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) • For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. • For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County 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 County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) 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. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (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. (f) 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. 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: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: • For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. • Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) • For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. • For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County 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 County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient.
Reference Number: 2023-003 Prior Year Finding: No Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: ARP17SL1 (5/23/2021 - 12/31/2026) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance (Modified Opinion) 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. Required information includes: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; v. Subaward Period of Performance Start and End Date; vi. Subaward Budget Period Start and End Date; vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; x. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiii. Identification of whether the award is R&D; and xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per section 200.414. (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. (f) 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. 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: Prince George’s County (the County) was unable to provide support that subawards it issued contained all required federal information nor that it properly monitored its subrecipients. Context: Five subrecipients were selected for testing, and the following exceptions were noted: • For one of five subrecipients, the County did not have a subaward agreement in place with the subrecipient. As such, all required information was not furnished to the subrecipient. • Five of five subaward agreements were missing the following required information: o Federal Award Identification Number (FAIN) • For two of five subrecipients, the County was unable to provide support that it conducted during the award monitoring. • For one of five subrecipients, the County was unable to provide support that it had verified that the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The County 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 County should review and enhance internal controls and procedures to ensure that all required information is included in all subawards, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed. Views of responsible officials: The Office of Community Relations (OCR) is reviewing and working to enhance internal controls and procedures to ensure all required information is included in the subaward, that proper subrecipient monitoring is conducted, and the evaluation of independent audits are performed. OCR is working with the subrecipient to gather payroll receipts and proof of the disbursement of funds to grantees selected through the RFPs managed by the subrecipient.
2023-045 Oregon Housing and Community Services Obtain documentation to support expenditures or pursue cost recovery Federal Awarding Agency: U.S. Department of Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance (COVID-19) Federal Award Numbers and Years: ERA 1, 2021 (COVID-19); ERA 2, 2021 (COVID-19) Compliance Requirements: Activities Allowed or Unallowed, Eligibility, Period of Performance Type of Finding: Noncompliance Prior Year Finding: N/A Questioned Costs: $96,624 (known) Criteria: 2 CFR 200.332(d); 2 CFR 200.501(g) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and are compliant with federal requirements. Additionally, department management is responsible for ensuring compliance when a contractor is responsible for program compliance. The department passed through funds to 17 community action agencies (subrecipients) and a third-party vendor (contractor) to provide program delivery. Program delivery included determining client eligibility and making payments for direct client assistance for rent, utilities, internet, and other housing related costs. During the fiscal year, the department performed program reviews for each of the subrecipients and the contractor to determine whether funds were paid to eligible clients for allowable activities. We selected eight subrecipient program reviews and the contractor review for testing. The department reviewed 175 client applications that were processed and approved for payment across the eight selected subrecipients. We reviewed the department’s program monitoring reports and identified 91 client applications with potential exceptions related to federal requirements. Our testing found 67 client applications with exceptions totaling $74,857 in questioned costs. The department reviewed a total of 60 individual client applications processed and approved for payment by the contractor. We reviewed the department’s program monitoring report and identified 16 client applications with potential exceptions related to federal requirements. Our testing found five client applications with exceptions totaling $21,767 in questioned costs. The majority of exceptions were due to a lack of sufficient documentation being maintained to ensure assistance was only provided to eligible clients for allowable costs within the applicable time period. We recommend department management coordinate with their subrecipients and contractor to obtain additional documentation to ensure compliance with federal requirements or to recover amounts paid that are not in compliance with federal requirements.
Reference Number: 2023-015 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Health Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525-02-03 (8/1/2020 - 7/31/2024), 5NU50CK000525-03-00 (8/1/2019 – 7/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must 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. 2 CFR section 200.332 also states that pass-through entities must: (d) 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). (e) 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. Section III – Federal Award Findings and Questioned Costs (Continued) (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. (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 be in compliance 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: Documentation of subaward agreements and monitoring activities was not maintained and was not available for audit. Context: The Department of Health (DOH) is the primary recipient of program funding and, therefore, has overall responsibility for activities funded by the program. DOH entered into an agreement with the Department of Education (DOE) to issue subawards to public and non-public schools on their behalf. Six of twenty-six subrecipients selected for testing received subawards issued by DOE. DOE was unable to provide copies of subaward agreements or documentation that subrecipient monitoring activities had been performed. Therefore, auditors were unable to verify compliance with Federal requirements for these subawards. Questioned costs: Undetermined. Cause: The agreement between DOH and DOE did not clearly state DOE’s responsibilities for subaward issuance and monitoring. As a result, DOE did not maintain copies of subaward agreements, nor was it able to provide documentation that it had performed risk assessments or monitoring activities for these subrecipients. In its oversight role, DOH did not review documentation maintained by DOE to ensure compliance with Federal subrecipient monitoring requirements. Effect: Auditors were unable to verify that subawards were issued in accordance with Federal requirements, that the subrecipients were eligible to receive program funding, nor that the subrecipients had been adequately monitored. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: DOH should review and enhance internal controls and procedures regarding agreements with other State departments to issue subawards on its behalf. Agreements should clearly define the responsibilities of other departments to ensure compliance with all Federal requirements. DOH should also periodically review the documentation maintained by other departments that issue subawards on its behalf to ensure it is adequate and is available for audit. DOE should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Documentation of subrecipient monitoring activities should be readily available for audit. Views of responsible officials: The Department of Health (DOH) will enhance its internal controls and procedures, regarding federal subawards issued by other New Jersey State departments and agencies on behalf of DOH. The Department’s Memorandum of Agreement (MOA) and Memorandum of Understanding (MOU) documents will be updated and enhanced to list and define the specific responsibilities and requirements of other departments and pass-through entities more clearly when issuing subawards with federal funding derived from DOH. If necessary, the updated MOA/MOU documents may also include an Exhibit specific to Subrecipient Monitoring, containing the federal Uniform Guidance compliance requirements including mandatory reporting of subgrantee performance indicators and listing records retention requirements for all documentation of monitored subrecipient activities.
Reference Number: 2023-015 Prior Year Finding: No Federal Agency: U.S. Department of Health and Human Services State Agency: Department of Health Federal Program: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), COVID-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Assistance Listing Number: 93.323 Award Number and Year: 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525 (8/1/2019 – 7/31/2024), 6NU50CK000525-02-03 (8/1/2020 - 7/31/2024), 5NU50CK000525-03-00 (8/1/2019 – 7/31/2024) Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria or specific requirement: Compliance – Per 2 CFR section 200.332(a), all pass-through entities must 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. 2 CFR section 200.332 also states that pass-through entities must: (d) 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). (e) 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. Section III – Federal Award Findings and Questioned Costs (Continued) (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. (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 be in compliance 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: Documentation of subaward agreements and monitoring activities was not maintained and was not available for audit. Context: The Department of Health (DOH) is the primary recipient of program funding and, therefore, has overall responsibility for activities funded by the program. DOH entered into an agreement with the Department of Education (DOE) to issue subawards to public and non-public schools on their behalf. Six of twenty-six subrecipients selected for testing received subawards issued by DOE. DOE was unable to provide copies of subaward agreements or documentation that subrecipient monitoring activities had been performed. Therefore, auditors were unable to verify compliance with Federal requirements for these subawards. Questioned costs: Undetermined. Cause: The agreement between DOH and DOE did not clearly state DOE’s responsibilities for subaward issuance and monitoring. As a result, DOE did not maintain copies of subaward agreements, nor was it able to provide documentation that it had performed risk assessments or monitoring activities for these subrecipients. In its oversight role, DOH did not review documentation maintained by DOE to ensure compliance with Federal subrecipient monitoring requirements. Effect: Auditors were unable to verify that subawards were issued in accordance with Federal requirements, that the subrecipients were eligible to receive program funding, nor that the subrecipients had been adequately monitored. Section III – Federal Award Findings and Questioned Costs (Continued) Recommendation: DOH should review and enhance internal controls and procedures regarding agreements with other State departments to issue subawards on its behalf. Agreements should clearly define the responsibilities of other departments to ensure compliance with all Federal requirements. DOH should also periodically review the documentation maintained by other departments that issue subawards on its behalf to ensure it is adequate and is available for audit. DOE should review and enhance internal controls and procedures to ensure that it maintains copies of all subaward agreements, that proper subrecipient monitoring is conducted, and that evaluation of independent audits is performed for all subrecipients. Documentation of subrecipient monitoring activities should be readily available for audit. Views of responsible officials: The Department of Health (DOH) will enhance its internal controls and procedures, regarding federal subawards issued by other New Jersey State departments and agencies on behalf of DOH. The Department’s Memorandum of Agreement (MOA) and Memorandum of Understanding (MOU) documents will be updated and enhanced to list and define the specific responsibilities and requirements of other departments and pass-through entities more clearly when issuing subawards with federal funding derived from DOH. If necessary, the updated MOA/MOU documents may also include an Exhibit specific to Subrecipient Monitoring, containing the federal Uniform Guidance compliance requirements including mandatory reporting of subgrantee performance indicators and listing records retention requirements for all documentation of monitored subrecipient activities.
Reference Number: 2023-007 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.332 – Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Verify that every subrecipient is audited as required by Subpart F – Audit Requirements of this part when it is expected that the subrecipient’s Federal award expended during the respective fiscal year equaled or exceeded the threshold set forth in section 200.501 Audit requirements. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County was not able to provide support to show it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F – Audit Requirements (Subpart F). Context: Exceptions were noted for 8 of 8 subrecipients selected for testing: • The County was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The County could not produce evidence of verification that the subrecipient’s Federal awards expended during the fiscal year were below the threshold set forth in section 200.501 Audit Requirements. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple years, and these discrepancies may not be properly monitored, detected, and corrected by the County personnel on a timely basis. Questioned Costs: Undetermined. Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2023-007 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.332 – Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Verify that every subrecipient is audited as required by Subpart F – Audit Requirements of this part when it is expected that the subrecipient’s Federal award expended during the respective fiscal year equaled or exceeded the threshold set forth in section 200.501 Audit requirements. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County was not able to provide support to show it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F – Audit Requirements (Subpart F). Context: Exceptions were noted for 8 of 8 subrecipients selected for testing: • The County was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The County could not produce evidence of verification that the subrecipient’s Federal awards expended during the fiscal year were below the threshold set forth in section 200.501 Audit Requirements. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple years, and these discrepancies may not be properly monitored, detected, and corrected by the County personnel on a timely basis. Questioned Costs: Undetermined. Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Reference Number: 2023-007 Federal Agency: U.S. Department of Treasury Federal Program: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Award Number and Year: 2021 Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Controls over Compliance, Other Matters Criteria or Specific Requirement: Compliance - 2 CFR Section 200.332 – Requirements for Pass-Through Entities states in part, that all pass-through entities must: (a) Verify that every subrecipient is audited as required by Subpart F – Audit Requirements of this part when it is expected that the subrecipient’s Federal award expended during the respective fiscal year equaled or exceeded the threshold set forth in section 200.501 Audit requirements. Control - Per 2 CDF 200.303(a), a non-Federal entity must: Establish a maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statues, regulations, and the terms and conditions of the federal awards. These internal controls should comply with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County was not able to provide support to show it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F – Audit Requirements (Subpart F). Context: Exceptions were noted for 8 of 8 subrecipients selected for testing: • The County was unable to provide support that it ensured the subrecipient was audited as required by Subpart F. The County could not produce evidence of verification that the subrecipient’s Federal awards expended during the fiscal year were below the threshold set forth in section 200.501 Audit Requirements. Cause: The County did not establish effective internal controls and procedures over subrecipient monitoring. Effect: Without ensuring subrecipients have obtained audits as required by Subpart F, there is an increased risk that subrecipients could be inappropriately spending and/or inaccurately tracking and reporting federal funds over multiple years, and these discrepancies may not be properly monitored, detected, and corrected by the County personnel on a timely basis. Questioned Costs: Undetermined. Recommendation: The County should review and enhance internal controls and procedures to ensure that evaluation of independent audits is performed. Views of Responsible Officials: The County agrees with this finding. See separate Correction Action Plan related to this finding.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-017 NH Department of Health and Human Services Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) and COVID-19 Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) Federal Award Numbers: 1B08Ti084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $7,720,172 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. The Department provided the most recent risk assessment performed for each of the 7 subrecipients selected for testwork. Per review of the risk assessments provided, we identified the following: 1. For 5 of the subrecipients, the risk assessment indicated that the subrecipients expenditure detail should be examined monthly to ensure compliance with contract requirements and applicable laws and rules. We were unable to determine if this procedure had been performed as part of the Department’s subrecipient monitoring process. 2. For the remaining 2 subrecipients the recommended monitoring procedures was left blank on the risk assessment and as such we are unable to verify what type of monitoring procedures should have been performed. B. The Department’s during the award monitoring for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified that for 2 of 7 subrecipients selected for testwork, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department review its existing policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials Management partially concurs with the finding above. Rejoinder As it relates to Bullet A above, we were not able to obtain documentation to support that the suggested procedures outlined within the risk assessment was performed. As it relates to Bullet B above, for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement.
Finding Reference Number: 2023-017 NH Department of Health and Human Services Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) and COVID-19 Substance Abuse Prevention and Treatment Block Grant (ALN #93.959) Federal Award Numbers: 1B08Ti084659-01, 1B08TI085821-01 Federal Award Year: 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $7,720,172 of federal funding to subrecipients. As part of our testing related subrecipient monitoring, we identified the following: A. The Department provided the most recent risk assessment performed for each of the 7 subrecipients selected for testwork. Per review of the risk assessments provided, we identified the following: 1. For 5 of the subrecipients, the risk assessment indicated that the subrecipients expenditure detail should be examined monthly to ensure compliance with contract requirements and applicable laws and rules. We were unable to determine if this procedure had been performed as part of the Department’s subrecipient monitoring process. 2. For the remaining 2 subrecipients the recommended monitoring procedures was left blank on the risk assessment and as such we are unable to verify what type of monitoring procedures should have been performed. B. The Department’s during the award monitoring for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified that for 2 of 7 subrecipients selected for testwork, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department review its existing policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials Management partially concurs with the finding above. Rejoinder As it relates to Bullet A above, we were not able to obtain documentation to support that the suggested procedures outlined within the risk assessment was performed. As it relates to Bullet B above, for of the 4 of the 7 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. It was evident through the invoice review that the Department often followed up on inconsistencies on hours worked with the subrecipient to help ensure the accuracy of the invoice reviewed. While this detailed review was performed, the Department did not perform any other monitoring procedures related to these 4 subrecipients to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. As such, it is unclear if the monitoring performed was sufficient to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement.
Finding Reference Number: 2023-023 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2023, $27,041,873 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 27 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: - Subrecipient unique entity identifier (not communicated for 19/27); - Federal Award Identification Number (FAIN) (not communicated for 27/27); - Identification of whether the award is R&D (not communicated for 27/27); and - Indirect cost rate for the federal award (including if the de minimis rate is charged) (not communicated for 27/27) B. The Department evaluated the subrecipient risk of noncompliance through a risk assessment for each of the 13 subrecipients selected for testwork. However, there was no formal risk assessment policy in place that indicated how frequently risk assessments should be performed. As a result, 5 subrecipients did not have risk assessments performed during the current year for purposes of determining the appropriate subrecipient monitoring response. These prior fiscal year(s) risk assessments were performed as of the following dates: September 2019, October and December 2021, May and June 2022. C. For each of the 13 subrecipients selected for testwork, the Department did not perform any during the award monitoring. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no UG report review policies and procedures in place. For the 13 subrecipients selected for testwork, 6 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 5 of 13 subrecipients, the subrecipient’s uniform guidance was not reviewed due to updated risk assessments not being performed in the current year (refer to item 2 above) • For 1 of 13 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report Cause The cause of the condition found was primarily due to the Department not performing their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-023 NH Department of Safety Disaster Grants – Public Assistance (Presidentially Declared Disasters) and COVID-19 Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Federal Award Numbers: FEMA-4622-DR-NH, FEMA-4624-DR-NH, FEMA-4457-DR-NH, FEMA-4370-DR, FEMA-4693-DR, FEMA-4355-DR, FEMA-4329-DR, FEMA-4516-DR-NH Federal Award Year: July 17-19, 2021, July 29-30, 2021, July 11-12, 2019, March 2-8, 2018, December 22-December 25, 2022, October 29-November 1, 2017, July 1-2, 2017, January 20, 2020 U.S. Department of Homeland Security Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: None Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Identify the Award and Applicable Requirements – Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.332(a)(3)). 2. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 3. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. 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 PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition As part of the Disaster Grants - Public Assistance program (DGPA), the New Hampshire Department of Safety - Homeland Security and Emergency Management (the Department) enters into grant agreements with local municipalities to provide reimbursement for expenditures incurred as a result of New Hampshire declared disasters. During the year ended June 30, 2023, $27,041,873 was passed through to 85 subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following: A. The Department communicates award information to subrecipients through the approved agreement. Per review of the agreement, for each of the 27 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332(a). Specifically, the following elements were not communicated: - Subrecipient unique entity identifier (not communicated for 19/27); - Federal Award Identification Number (FAIN) (not communicated for 27/27); - Identification of whether the award is R&D (not communicated for 27/27); and - Indirect cost rate for the federal award (including if the de minimis rate is charged) (not communicated for 27/27) B. The Department evaluated the subrecipient risk of noncompliance through a risk assessment for each of the 13 subrecipients selected for testwork. However, there was no formal risk assessment policy in place that indicated how frequently risk assessments should be performed. As a result, 5 subrecipients did not have risk assessments performed during the current year for purposes of determining the appropriate subrecipient monitoring response. These prior fiscal year(s) risk assessments were performed as of the following dates: September 2019, October and December 2021, May and June 2022. C. For each of the 13 subrecipients selected for testwork, the Department did not perform any during the award monitoring. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted there were no UG report review policies and procedures in place. For the 13 subrecipients selected for testwork, 6 subrecipients were identified in which the Department did not review the most recent uniform guidance report issued. Specifically, we noted: • For 5 of 13 subrecipients, the subrecipient’s uniform guidance was not reviewed due to updated risk assessments not being performed in the current year (refer to item 2 above) • For 1 of 13 subrecipients, the current year risk assessment was performed prior to the receipt of the subrecipient’s uniform guidance report and management did not go back to review the report Cause The cause of the condition found was primarily due to the Department not performing their sub monitoring internal controls in accordance with written formal policies and procedures. Questioned Costs None. Recommendation We recommend that the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(a-h) and 2 CFR section 200.501(h). View of Responsible Officials: Management concurs with the finding above.
2023-001: Significant Deficiency - Audit Completion and Submission to the Federal Government Compliance Area: Reporting (L) Criteria: Single Audits under 2 CFR Part 200 Subpart F 200.501 - Audit Requirements are required to be submitted through the Federal Clearinghouse nine months from the recipient's year-end. Condition: For the fourth year in the row the County has not been able to begin the audit early enough to meet the nine-month submission deadline. Cause and Effect: The County has been unable to close the financial records and submit the required information to the auditors in a timely manner, resulting in non-compliance. Repeat Finding: Yes Recommendation: We recommend that the County submit the required information to the auditors in a timely manner in an effort to meet this deadline. To achieve this goal, it may require the County to either increase staffing levels or hire a consultant.
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2022-010 Condition: For 3 out of 3 selections, the Federal award identification number (FAIN) and the subrecipient's unique entity identifier (UEI) were not disclosed on the subaward. For 3 out of 3 selections, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR §200.303: The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Pursuant to 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.330, .331, and .501(h), a pass-through entity must identify the award and applicable requirements, evaluate risk, monitor, and ensure accountability of subrecipients. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (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. (c) 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. (e) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Mayor’s Office of Homeless Services (MOHS) did not maintain adequate documentation of the requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect: MOHS was not in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that MOHS establish and implement controls for the program and prepare and maintain a written plan to perform risk assessments on potential subrecipients. Additionally, we recommend that MOHS provides training on the Uniform Guidance requirements related to subrecipient monitoring. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, we were unable to verify the subrecipient 's active registration on SAM.gov. For 1 out of 1 selection, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Baltimore City Health Department (BCHD) did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD was not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, we were unable to verify the subrecipient 's active registration on SAM.gov. For 1 out of 1 selection, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Baltimore City Health Department (BCHD) did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD was not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.
U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Condition: For 1 out of 1 selection, management was unable to provide evidence that subrecipient monitoring was performed to ensure compliance with accounting requirements. For 1 out of 1 selection, we were unable to verify the subrecipient 's active registration on SAM.gov. For 1 out of 1 selection, there was no evidence that the prior year Single Audit Report was reviewed. Criteria: In accordance with 2 CFR 200.303: Internal Control, The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. In accordance with 2 CFR §25.300: (a) A recipient may not make a subaward to a subrecipient unless that subrecipient has obtained and provided to the recipient a unique entity identifier. Subrecipients are not required to complete full SAM registration to obtain a unique entity identifier. (b) A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient has obtained a unique entity identifier as described in paragraph (a) of this section. According to 2 CFR §200.332, all pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the Federal award identification including the subrecipient's unique entity identifier, Federal Award Identification Number (FAIN), identification of whether the award is R&D and indirect cost rate for the Federal award. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. (f) Verify that every subrecipient is audited as required by 2 CFR § 200.331 when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Cause: The Baltimore City Health Department (BCHD) did not have proper controls in place to ensure the subrecipient monitoring requirements of the grant were met. Effect: BCHD was not be in compliance with the subrecipient monitoring requirements of the grant. Questioned Costs: Unknown. Recommendation: We recommend the City establish and implement controls to maintain compliance with subrecipient monitoring requirements. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report. Auditor’s Conclusion: Finding remains as stated.