FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
FINDING NO: 2023-014 STATE AGENCY: State of Oklahoma FEDERAL AGENCY: U.S. Department of the Treasury ALN: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD NUMBER: N/A FEDERAL AWARD YEAR: 2023 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $0 Criteria: 2 CFR § 200.332(d) – Requirements for Pass-through Entities states in part, “All pass-through entities must: … (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. 2 CFR 200.332 states in part, “All pass-through entities must: … (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.” Condition and Context: The State of Oklahoma transferred all CSLFRF funds (except for administrative funds used by OMES-Grants Management Office (GMO) and the Legislative Service Bureau) to state agencies for them to execute projects they are charged with administering. The Oklahoma State Department of Health (agency #340), Health Care Workforce Training Commission (agency #619), and Department of Human Services (agency #830) had the material subrecipient monitoring activity for SFY 2023. These three state agencies notified their subrecipients of $750,000 federal expenditure threshold requiring a Single Audit per 2 CFR § 200.501 - Audit Requirements; however, they failed to track subrecipients that expended federal expenditures for CSLFRF, or in combination with other federal programs, to ensure that every subrecipient expending over $750,000 obtained a Single Audit. Cause: State agencies 340, 619, and 830 did not have sufficient processes or internal controls in place to ensure subrecipient Single Audits were tracked in accordance with 2 CFR § 200.332(d) and (f). Effect: State agencies 340, 619, and 830 may not be aware of potential subrecipient Single Audits with noncompliance issues related to the CSLFRF program. In addition, the agencies may fail to ensure that the subrecipient took appropriate corrective action on findings within the required timeframe. Recommendation: We recommend state agencies 340, 619, and 830 develop policies and procedures and internal controls to ensure that all CSLFRF subrecipients are tracked to determine if the subrecipient had $750,000 in total federal expenditures for the year. In addition, we recommend state agencies utilize a track sheet that documents the following: • Subrecipient SFY CSLFRF expenditures • If subrecipient is subject to single audit (y/n) • If subrecipient had CSLFRF findings (y/n) • Concerns with CSLFRF findings • Date single audit is received from subrecipient or obtained from the federal audit clearing house • Single Audit Report period (period covered by the single audit) • Whether the state agency received a copy of the required audit from the subrecipient within 9 months of the subrecipient's fiscal year end • Dates of follow-ups made to the subrecipient requesting single audits • Notes to document additional information such as delays in audit reports • Whether the state agency issued a management decision on audit findings within 6 months after receipt of the subrecipient's audit report • Whether the state agency ensured that subrecipients took appropriate and timely corrective action on all CSLFRF audit findings Views of Responsible Official(s) Contact Person: OMES: Parker Wise 619: Sara Librandi, Kami Fullingim 340: Diane Brown, Danielle Smith, Tracey Douglas 830: Jaretta Murphy, Lindsey Kanaly, Danielle Durkee, Katey Campbell Anticipated Completion Date: 6/30/2025 Corrective Action Planned: The Office of Management Enterprise Services – Grants Management Office partially agrees with the finding. Please see the corrective action plan located in the corrective action plan section of this report. Auditor Response: State agency 830 states “a process is already in place through the Office of Inspector General (OIG) to identify subrecipients exceeding the $750,000 threshold”; however, subrecipients with expenditures below the threshold must also be tracked to ensure total federal expenditures from all federal awards obtain a Single Audit. 2 CFR 200.332 states in part, “All pass-through entities must: … (f) Verify that every subrecipient is audited”. Therefore, state agency 830 acting as the pass-through entity must verify every subrecipient is audited. In addition, contractual language requiring the subrecipient submit a single audit if the threshold is met does not release the passthrough entity of ensuring the subrecipient’s total federal expenditures are tracked. We have encountered instances where subrecipients fail to provide single audits to pass-through entities; therefore, increasing the chances of the passthrough entity not issuing a management decision for applicable audit findings pertaining only to the federal award provided.
Federal Agency: Department of Health and Human Services Federal Program: Block Grants for Community Mental Health Services (93.958) Federal Award Numbers: 6B09SM083819-01M001; 6B09SM083990-01M002; 1B09SM085374-01; 1B09SM085374-01; 1B09SM085902-01; 6B09SM086027-01M003 Federal Award Years: 2021 and 2022 State Agency: Office of Mental Health Reference: 2023-017 Criteria Subrecipient monitoring Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, Section 352(a) states all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information include: (1) Federal Award Identification. 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 Section 75.2 Federal award date) of award to the recipient by the HHS awarding agency; v) Subaward Period of Performance Start and End Date; vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current obligation; viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); x) Name of HHS awarding agency, pass-through entity, and contract information for awarding official of the pass-through entity; xi) CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; xii) Identification of whether the award is R&D; and xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per Section 75.414). Title 45 Code of Federal Regulations Part 75, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (45 CFR 75), section 352(b) states all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal Statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring as 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, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of HHS awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a HHS awarding agency). Additionally, 45 CFR 75.352(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 75.521. 45 CFR 74.352(e) states depending upon the pass-through entity's assessment of risk posed by the sub recipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program related matters; and (2) Performing on-site reviews of the subrecipient's program operations; Further, 45 CFR 75.352(f) states the pass-through entity must 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. Internal controls Lastly, 45 CFR 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. 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 During the fiscal year ended March 31, 2023, the Office of Mental Health (the Office) passed through $100,181,501 under the Block Grants for Community Mental Health Services program, to local districts and providers (subrecipients) to provide programmatic and administrative services. As part of the funding arrangement, the local districts and providers (subrecipients) are responsible for carrying out the programmatic services and use the funds to provide comprehensive, community‐based mental health services to adults with serious mental illnesses and to children with serious emotional disturbances and to monitor progress in implementing a comprehensive, community based mental health system. Funds are used for prevention, treatment, recovery support, and other services to supplement Medicaid, Medicare, and private insurance services. When subawards are made to subrecipients, the pass-through entities are required to communicate certain award information. The Office’s policies and procedures are not designed to ensure that award notifications are provided to subrecipients as required by 45 CFR 75.352(a). During our testwork of 40 subrecipient award notifications, we noted the following: 1. For 8 subrecipients, the Federal Award Identification Number (FAIN) was not provided. 2. For 11 subrecipients, which are all New York State Counties, there was no notification of access to records. 3. For 22 of the subrecipients, there was no notification of the DUNS number. All pass-through entities are required to perform a risk assessment over each subrecipient’s risk of noncompliance for purposes of determining appropriate subrecipient monitoring procedures. The Office did not perform an annual risk assessment process related to its subrecipients as required by 45 CFR 75.352(b). Additionally, all pass-through entities must monitor the activities of the subrecipient which must include review of financial and performance reports, follow up to ensure the subrecipient takes timely and appropriate action on any deficiencies identified, and issue a management decision for audit findings. The Office did not monitor and retain documentation of review of financial and performance reports, follow up to ensure appropriate action on any deficiencies identified, nor issue a management decision for audit findings. Lastly, all pass-through entities are required to verify each subrecipient is audited, if required. The Office did not ensure that all required single audits of the program’s subrecipients were received, reviewed, followed-up, or appropriate action was taken and as necessary issued a management decision pertaining to the audit finding in accordance with 45 CFR 75, as applicable. Cause The condition found is primarily due to the lack of written policies and procedures to ensure that: 1. all required award identification information per 45 CFR 75.352(a) is communicated to the subrecipients for each federal subaward period; 2. an appropriate risk assessment process is in place per 45 CFR 75.352(b); 3. during award monitoring procedures are performed per 45 CFR 75.352(d); and 4. review of the subrecipient single audit reports are performed per 45 CFR 75.352(f). Possible Asserted Effect Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures, failure to review financial and performance reports of subrecipients, as well as failure to obtain and review subrecipient single audit reports may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Questioned Costs Cannot be determined. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that the Office enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients of the Office as data elements change or funding is passed-through. We recommend that the Office implement policies, procedures, and internal controls to ensure that risk assessments of subrecipients are performed on an annual basis to determine appropriate monitoring of subrecipients is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Lastly, we recommend that the Office implement policies, procedures, and internal controls to track and review all subrecipients’ single audit submissions per 45 CFR 75.252(f).
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Federal Agency: Department of Health and Human Services Federal Program: Block Grants for Community Mental Health Services (93.958) Federal Award Numbers: 6B09SM083819-01M001; 6B09SM083990-01M002; 1B09SM085374-01; 1B09SM085374-01; 1B09SM085902-01; 6B09SM086027-01M003 Federal Award Years: 2021 and 2022 State Agency: Office of Mental Health Reference: 2023-017 Criteria Subrecipient monitoring Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards, Section 352(a) states all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information include: (1) Federal Award Identification. 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 Section 75.2 Federal award date) of award to the recipient by the HHS awarding agency; v) Subaward Period of Performance Start and End Date; vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current obligation; viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); x) Name of HHS awarding agency, pass-through entity, and contract information for awarding official of the pass-through entity; xi) CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; xii) Identification of whether the award is R&D; and xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per Section 75.414). Title 45 Code of Federal Regulations Part 75, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (45 CFR 75), section 352(b) states all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal Statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring as 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, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of HHS awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a HHS awarding agency). Additionally, 45 CFR 75.352(d) states all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 75.521. 45 CFR 74.352(e) states depending upon the pass-through entity's assessment of risk posed by the sub recipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program related matters; and (2) Performing on-site reviews of the subrecipient's program operations; Further, 45 CFR 75.352(f) states the pass-through entity must 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. Internal controls Lastly, 45 CFR 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. 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 During the fiscal year ended March 31, 2023, the Office of Mental Health (the Office) passed through $100,181,501 under the Block Grants for Community Mental Health Services program, to local districts and providers (subrecipients) to provide programmatic and administrative services. As part of the funding arrangement, the local districts and providers (subrecipients) are responsible for carrying out the programmatic services and use the funds to provide comprehensive, community‐based mental health services to adults with serious mental illnesses and to children with serious emotional disturbances and to monitor progress in implementing a comprehensive, community based mental health system. Funds are used for prevention, treatment, recovery support, and other services to supplement Medicaid, Medicare, and private insurance services. When subawards are made to subrecipients, the pass-through entities are required to communicate certain award information. The Office’s policies and procedures are not designed to ensure that award notifications are provided to subrecipients as required by 45 CFR 75.352(a). During our testwork of 40 subrecipient award notifications, we noted the following: 1. For 8 subrecipients, the Federal Award Identification Number (FAIN) was not provided. 2. For 11 subrecipients, which are all New York State Counties, there was no notification of access to records. 3. For 22 of the subrecipients, there was no notification of the DUNS number. All pass-through entities are required to perform a risk assessment over each subrecipient’s risk of noncompliance for purposes of determining appropriate subrecipient monitoring procedures. The Office did not perform an annual risk assessment process related to its subrecipients as required by 45 CFR 75.352(b). Additionally, all pass-through entities must monitor the activities of the subrecipient which must include review of financial and performance reports, follow up to ensure the subrecipient takes timely and appropriate action on any deficiencies identified, and issue a management decision for audit findings. The Office did not monitor and retain documentation of review of financial and performance reports, follow up to ensure appropriate action on any deficiencies identified, nor issue a management decision for audit findings. Lastly, all pass-through entities are required to verify each subrecipient is audited, if required. The Office did not ensure that all required single audits of the program’s subrecipients were received, reviewed, followed-up, or appropriate action was taken and as necessary issued a management decision pertaining to the audit finding in accordance with 45 CFR 75, as applicable. Cause The condition found is primarily due to the lack of written policies and procedures to ensure that: 1. all required award identification information per 45 CFR 75.352(a) is communicated to the subrecipients for each federal subaward period; 2. an appropriate risk assessment process is in place per 45 CFR 75.352(b); 3. during award monitoring procedures are performed per 45 CFR 75.352(d); and 4. review of the subrecipient single audit reports are performed per 45 CFR 75.352(f). Possible Asserted Effect Failure to adequately communicate award identification information could result in the subrecipient not being able to adequately track and report the subawards received resulting in errors being reported on the schedule of expenditures of federal awards within a subrecipient’s annual single audit report and not being able to comply with required terms and conditions of the federal award. Failure to perform an annual risk assessment to determine appropriate subrecipient monitoring procedures, failure to review financial and performance reports of subrecipients, as well as failure to obtain and review subrecipient single audit reports may result in insufficient monitoring procedures being performed to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Questioned Costs Cannot be determined. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Recommendation We recommend that the Office enhance its processes and internal controls over its reporting to the subrecipients of the federal program to ensure all award identification information required under 45 CFR 75.352(a) is provided to the subrecipients of the Office as data elements change or funding is passed-through. We recommend that the Office implement policies, procedures, and internal controls to ensure that risk assessments of subrecipients are performed on an annual basis to determine appropriate monitoring of subrecipients is performed in accordance with 45 CFR 75.352(d) and 45 CFR 75.352(e). Lastly, we recommend that the Office implement policies, procedures, and internal controls to track and review all subrecipients’ single audit submissions per 45 CFR 75.252(f).
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
Condition: The Organization did not submit the audit and Data Collection form within the nine-month due date for the fiscal year 2022. Criteria: According to the OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a), non-Federal entities that expend $750,000 or more in a year in Federal awards shall have a single or program-specific audit conducted for that year in accordance with the provisions of these parts. The audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. If the due date falls on a Saturday, Sunday, or Federal holiday, the reporting package is due the next business day. Questioned Costs: There are no questioned costs. Cause: The Organization has encountered staffing issues and consistency in the fiscal office over the past couple of years which has made it difficult for the management team to close the books in a timely manner and caused audit delays. Effect: Since the Organization submitted the audit and Data Collection form late, they are not in compliance with OMB Circular A–133, Subpart B--Audits §___.200(a), and Uniform Guidance, 2 CFR 200.501(a). Recommendation: RBT recommends the Organization develop a closing checklist and timeline so that the books are closed and the audit can be completed in a timely manner. Perspective: This is a systematic issue, in that controls over the requirement have not been developed to ensure no issues arise. Repeat: This is not a repeat finding. Responsible Offical's Response: The Organization agrees with the finding. See attached corrective action plan.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Agency: Department of Commerce and Department of Health and Human Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing and Development and Testing a Field-based Hazard/Near-Miss Sharing System for Commercial Fishing Vessels Award Numbers: 70NANB21H038 and U01OH012288 Assistance Listing Title: Measurement and Engineering Research and Standards and Occupational Safety and Health Program Assistance Listing Number: 11.609 and 93.262 Award Year: FY 2022 Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the 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 2 CFR 200.501. Condition Through our testing of 4 subrecipients out of a population of 10, we were able to obtain a documented initial risk assessment for each subrecipient selected and other evidence of monitoring such as meetings with the subrecipients. However, we were unable to obtain evidence that the Company obtained and reviewed the annual Uniform Guidance report or annual audited financial statements (if the entity was not subject to a Uniform Guidance audit) for each subrecipient selected for testing. Cause The Company performed an initial risk assessment but did not understand that obtaining the Uniform Guidance reports or financial statements needed to be completed annually as part of their subrecipient monitoring procedures. Effect The lack of an annual review of subrecipient audits may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend the Company implement a policy to review Uniform Guidance reports (or audited financial statements to the extent Uniform Guidance reports are not available) on an annual basis. When reviewing the reports, they should understand the type of opinion(s) expressed and whether there were any findings associated with their awards, document their review and assess whether there is any change in the risk assessment and subsequent monitoring needed of each subrecipient. Management? Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Agency: Department of Commerce and Department of Health and Human Services Award Names: Standards/Guidance for Rapid Qualification of Metal-Based Additive Manufacturing and Development and Testing a Field-based Hazard/Near-Miss Sharing System for Commercial Fishing Vessels Award Numbers: 70NANB21H038 and U01OH012288 Assistance Listing Title: Measurement and Engineering Research and Standards and Occupational Safety and Health Program Assistance Listing Number: 11.609 and 93.262 Award Year: FY 2022 Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the 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 2 CFR 200.501. Condition Through our testing of 4 subrecipients out of a population of 10, we were able to obtain a documented initial risk assessment for each subrecipient selected and other evidence of monitoring such as meetings with the subrecipients. However, we were unable to obtain evidence that the Company obtained and reviewed the annual Uniform Guidance report or annual audited financial statements (if the entity was not subject to a Uniform Guidance audit) for each subrecipient selected for testing. Cause The Company performed an initial risk assessment but did not understand that obtaining the Uniform Guidance reports or financial statements needed to be completed annually as part of their subrecipient monitoring procedures. Effect The lack of an annual review of subrecipient audits may result in ineligible subrecipients receiving federal awards, subrecipient findings not being fully remediated and other monitoring procedures (based on risk level) not being performed. Questioned Costs None noted. Recommendation We recommend the Company implement a policy to review Uniform Guidance reports (or audited financial statements to the extent Uniform Guidance reports are not available) on an annual basis. When reviewing the reports, they should understand the type of opinion(s) expressed and whether there were any findings associated with their awards, document their review and assess whether there is any change in the risk assessment and subsequent monitoring needed of each subrecipient. Management? Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report.
Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Finding 2022-001: Identification of Federal Award Compliance Requirements Assistance Listing Number: 19.510 Federal Program: U.S. Refugee Admissions Program Federal Agency: U.S. Department of State Pass-Through Entity: Church World Service Type of Finding: Material Weakness in Internal Control over Compliance Criteria: Per Title 2 of the Code of Federal Regulations (2 CFR) section 200.501, non-federal entities that expend $750,000 or more during the non-federal entity’s fiscal year in federal awards must have a Single Audit conducted in accordance with 2 CFR section 200.514. Condition: We noted Team Rubicon received a federal subaward in excess of $750,000 requiring a Single Audit. Cause: The error was primarily due to a misunderstanding of the $750,000 limit above which a Single Audit would be required. Effect or Potential Effect: A failure to identify federal compliance requirements could result in Team Rubicon not being in compliance with federal statutes, regulations and the terms and conditions of federal awards. Questioned Costs: None identified Context: During the year ended December 31, 2022, Team Rubicon received a grant in excess of $750,000 from a recipient of a federal award, making Team Rubicon a subrecipient of the award and subject to certain federal compliance requirements including a Single Audit. Repeat Finding: Not applicable Recommendation: Management is responsible for establishing controls and procedures to ensure contracts and grants are reviewed for key terms and conditions that may indicate federal funding to ensure the proper identification and compliance with federal statutes, regulations and the terms and conditions of the federal awards including the requirement for a Single Audit. Views of Responsible Official: Management agrees and acknowledges the finding.
Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Agency/Pass-through Grantor Department of the Treasury, Department of Health and Human Services passed through the State of Alaska Department of Health and Social Services ALN and Program Name 21.027 - Coronavirus State and Local Fiscal Recovery Funds – COVID 19 21.023 – Emergency Rental Assistance Program – COVID 19 93.323 – COVID-19-Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Award # 21.027 – 1505-0271 21.023 – ERA-2101060120 (ERA 1); ERA2-0469 (ERA 2) 93.323 – C0621-570-BB Award Year 21.027 – 2022 21.023 - 2022 93.323 – 3/15/2021-6/30/2022 Criteria or Specific Requirement 2 CFR 200.332 requires pass-through entities to ensure that subrecipients comply with the terms and conditions of 2 CFR 200.501 related to audit requirements. This includes ensuring that every subaward is (1) clearly identified to the subrecipient as a subaward; (2) includes the necessary information at the time of the subaward for subrecipient reporting on federal awards (2 CFR 200.332) and (3) includes requirement to follow 2 CFR 200.501 if expenditure thresholds are met. This also includes verifying that every subrecipient is audited as required by 2 CFR Subpart F if the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition During our testing of subrecipient monitoring, we noted all 18 of the subrecipient agreements tested did not include language clearly identifying the federal program from which the subaward originated, or the applicable requirements from 2 CFR 300.332 and Subpart F. We also noted for all 18 subrecipients tested that the Municipality did not verify whether subrecipients were audited in accordance with 2 CFR 200.501 where applicable. Cause The issuance of subrecipient agreements for these grants related to new funding streams in response to the COVID-19 pandemic. Significant amounts of funding were provided in a short period of time, and systems to distribute these monies were newly created and implemented. The standard award agreements were not reviewed in advance to ensure adherence to federal requirements. Staff were not fully trained on the informational requirements and monitoring responsibilities related to audit requirements. Effect or Potential Effect Subrecipients may be unaware and not in compliance with the requirements of 2 CFR Part 200. Questioned Costs Not applicable. Context For ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds, we tested a sample of 10 subawards totaling to $28,079,600 from a population of 37 totaling to $37,052,621. For ALN 21.023 - Emergency Rental Assistance Program, we tested all 3 subawards within the population totaling to $10,900,177. For ALN 93.323 – COVID-19-Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), we tested all 5 subawards within the population totaling to $5,086,923. As noted in the condition, we identified exceptions for 18 subrecipient agreements tested. All samples tested were selected using nonstatistical sampling methods and were not statistically valid samples. Identification as a Repeat Finding Yes. This finding was reported as Finding 2021-002 in the prior audit. Recommendation Management should establish policies to ensure subawards contain required federal award information. In addition, procedures should be established to monitor subrecipient compliance with audit requirements of 2 CFR 200.501. Views of Responsible Officials Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and procedures related to subrecipient monitoring.
Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Agency/Pass-through Grantor Department of the Treasury, Department of Health and Human Services passed through the State of Alaska Department of Health and Social Services ALN and Program Name 21.027 - Coronavirus State and Local Fiscal Recovery Funds – COVID 19 21.023 – Emergency Rental Assistance Program – COVID 19 93.323 – COVID-19-Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Award # 21.027 – 1505-0271 21.023 – ERA-2101060120 (ERA 1); ERA2-0469 (ERA 2) 93.323 – C0621-570-BB Award Year 21.027 – 2022 21.023 - 2022 93.323 – 3/15/2021-6/30/2022 Criteria or Specific Requirement 2 CFR 200.332 requires pass-through entities to ensure that subrecipients comply with the terms and conditions of 2 CFR 200.501 related to audit requirements. This includes ensuring that every subaward is (1) clearly identified to the subrecipient as a subaward; (2) includes the necessary information at the time of the subaward for subrecipient reporting on federal awards (2 CFR 200.332) and (3) includes requirement to follow 2 CFR 200.501 if expenditure thresholds are met. This also includes verifying that every subrecipient is audited as required by 2 CFR Subpart F if the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition During our testing of subrecipient monitoring, we noted all 18 of the subrecipient agreements tested did not include language clearly identifying the federal program from which the subaward originated, or the applicable requirements from 2 CFR 300.332 and Subpart F. We also noted for all 18 subrecipients tested that the Municipality did not verify whether subrecipients were audited in accordance with 2 CFR 200.501 where applicable. Cause The issuance of subrecipient agreements for these grants related to new funding streams in response to the COVID-19 pandemic. Significant amounts of funding were provided in a short period of time, and systems to distribute these monies were newly created and implemented. The standard award agreements were not reviewed in advance to ensure adherence to federal requirements. Staff were not fully trained on the informational requirements and monitoring responsibilities related to audit requirements. Effect or Potential Effect Subrecipients may be unaware and not in compliance with the requirements of 2 CFR Part 200. Questioned Costs Not applicable. Context For ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds, we tested a sample of 10 subawards totaling to $28,079,600 from a population of 37 totaling to $37,052,621. For ALN 21.023 - Emergency Rental Assistance Program, we tested all 3 subawards within the population totaling to $10,900,177. For ALN 93.323 – COVID-19-Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), we tested all 5 subawards within the population totaling to $5,086,923. As noted in the condition, we identified exceptions for 18 subrecipient agreements tested. All samples tested were selected using nonstatistical sampling methods and were not statistically valid samples. Identification as a Repeat Finding Yes. This finding was reported as Finding 2021-002 in the prior audit. Recommendation Management should establish policies to ensure subawards contain required federal award information. In addition, procedures should be established to monitor subrecipient compliance with audit requirements of 2 CFR 200.501. Views of Responsible Officials Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and procedures related to subrecipient monitoring.
Finding 2022-009 Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Controls Over Compliance Agency/Pass-through Grantor Department of the Treasury, Department of Health and Human Services passed through the State of Alaska Department of Health and Social Services ALN and Program Name 21.027 - Coronavirus State and Local Fiscal Recovery Funds – COVID 19 21.023 – Emergency Rental Assistance Program – COVID 19 93.323 – COVID-19-Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Award # 21.027 – 1505-0271 21.023 – ERA-2101060120 (ERA 1); ERA2-0469 (ERA 2) 93.323 – C0621-570-BB Award Year 21.027 – 2022 21.023 - 2022 93.323 – 3/15/2021-6/30/2022 Criteria or Specific Requirement 2 CFR 200.332 requires pass-through entities to ensure that subrecipients comply with the terms and conditions of 2 CFR 200.501 related to audit requirements. This includes ensuring that every subaward is (1) clearly identified to the subrecipient as a subaward; (2) includes the necessary information at the time of the subaward for subrecipient reporting on federal awards (2 CFR 200.332) and (3) includes requirement to follow 2 CFR 200.501 if expenditure thresholds are met. This also includes verifying that every subrecipient is audited as required by 2 CFR Subpart F if the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Condition During our testing of subrecipient monitoring, we noted all 18 of the subrecipient agreements tested did not include language clearly identifying the federal program from which the subaward originated, or the applicable requirements from 2 CFR 300.332 and Subpart F. We also noted for all 18 subrecipients tested that the Municipality did not verify whether subrecipients were audited in accordance with 2 CFR 200.501 where applicable. Cause The issuance of subrecipient agreements for these grants related to new funding streams in response to the COVID-19 pandemic. Significant amounts of funding were provided in a short period of time, and systems to distribute these monies were newly created and implemented. The standard award agreements were not reviewed in advance to ensure adherence to federal requirements. Staff were not fully trained on the informational requirements and monitoring responsibilities related to audit requirements. Effect or Potential Effect Subrecipients may be unaware and not in compliance with the requirements of 2 CFR Part 200. Questioned Costs Not applicable. Context For ALN 21.027 - Coronavirus State and Local Fiscal Recovery Funds, we tested a sample of 10 subawards totaling to $28,079,600 from a population of 37 totaling to $37,052,621. For ALN 21.023 - Emergency Rental Assistance Program, we tested all 3 subawards within the population totaling to $10,900,177. For ALN 93.323 – COVID-19-Epidemiology and Laboratory Capacity for Infectious Diseases (ELC), we tested all 5 subawards within the population totaling to $5,086,923. As noted in the condition, we identified exceptions for 18 subrecipient agreements tested. All samples tested were selected using nonstatistical sampling methods and were not statistically valid samples. Identification as a Repeat Finding Yes. This finding was reported as Finding 2021-002 in the prior audit. Recommendation Management should establish policies to ensure subawards contain required federal award information. In addition, procedures should be established to monitor subrecipient compliance with audit requirements of 2 CFR 200.501. Views of Responsible Officials Management concurs with the finding and will adhere to the corrective action plan included in this report. Management plans to revise policies and procedures related to subrecipient monitoring.
Finding No. 2022-001 Grantor: U.S. Small Business Administration Program Name: COVID-19 – Shuttered Venue Operators Grant Assistance Listing Number: 59.075 Material noncompliance with laws and regulations and significant deficiency in internal controls over Federal awards Criteria: The Association was required to have an audit in compliance with the requirements of 2 CFR Section 200.501 and submit its audit to the Federal Audit Clearinghouse as required by 2 CFR Section 200.512, which was due by September 30, 2023. Condition: The audit was not completed timely. Cause: The internal control procedures for the Association had not been updated for the additional reporting requirements for the Shuttered Venue Operators Grant. Effect or Potential Effect: Untimely submissions hinders the grantor’s administration, monitoring, and decision-making processes. Recommendation: We recommend the strengthening of internal controls procedures over the award process to ensure that all existing and any new compliance requirements be communicated to all involved in the process to ensure timely adherence to all or any requirements. Views of Responsible Officials: See corrective action plan.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.
Assistance Listing Number, Federal Agency, and Program Name: All major programs Federal Award Identification Number and Year: 2022 Finding Type – Material weakness over compliance Repeat Finding - No Criteria – Per 2 CFR 200.512 (a) (1), the audit must be completed, and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted 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. Per 2 CFR 200.501 (b), a non-Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal awards must have a single audit conducted in accordance with § 200.514. Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended December 31, 2022. Context – The County’s single audit was not completed prior to the due date of data collection form. Identification of How Questioned Costs Were Computed – N/A Questioned Costs – None Cause – The County’s Schedule of Federal Awards was not prepared in a timely manner. Effect – Data collection forms were not submitted on time. Recommendation – We recommend that the County develop a reliable system to close the financial records in a timely manner. View of Responsible Officials and Corrective Action Plan – The 2022 Single Audit was not completed within the required timeline primarily as a result of staff turnover and resource requirements surrounding the implementation of a new ERP system in 2023. New staff have been assigned to the preparation of the Schedule of Expenditures of Federal Awards (SEFA) beginning in 2023 and the new system went live in October 2023.