2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
2022-001 ? Subrecipient Monitoring Cluster: Research and Development Sponsoring Agency: Various agencies Award Names: Various awards Award Numbers: Various award numbers Assistance Listing Title: Various assistance listing titles Assistance Listing Number: Various assistance listing numbers Award Year: 2021 ? 2022 Pass-through entity: Various pass-through entities 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. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, University procedures include (amongst other items) obtaining a certification letter from the subrecipient, performing an initial risk assessment on all subrecipients and updating that risk assessment based on the Office of Sponsored Programs judgement. Condition Through our testing of 11 subrecipients, we noted the following: - For 4 of the 11 samples of subrecipients selected, we were unable to obtain the initial risk assessment form. - For 2 of the 11 samples of subrecipients selected, we were unable to obtain the certification letter. - For 8 of the 11 samples of subrecipients selected, there was a current year modification to the subaward agreement, however, we were unable to obtain evidence of management?s judgement with regards to whether a risk assessment form was necessary to be completed in accordance with the University?s procedures. - For 1 of the 11 samples of subrecipients selected, we were unable to obtain the original subrecipient commitment form. - For 11 of the 11 samples of subrecipients selected, we were unable to obtain evidence of the University?s annual review of the Uniform Guidance report. Cause The University indicated subrecipient reviews were not consistently performed in accordance with 2 CFR. Certain risk assessment forms were completed in prior years; however, the Office of Sponsored Programs was unable to locate the original completed forms. Additionally, due to reduced staffing levels within the Office of Sponsored Programs, the Uniform Guidance requirements (and related University procedures) around subrecipient reviews were not consistently performed and/or documented. Effect The lack of written procedures, and annual review of subrecipient awards in accordance with the procedures, 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 that the University reassess the design of its controls around subrecipient monitoring both prior to the execution of a subaward agreement and during the ongoing monitoring process. The University should also update its procedures related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management?s Views and Corrective Action Plan Management?s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings and status.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding 2022-003 – Subrecipient Monitoring– Material Weakness and Noncompliance Federal Program: Formula Grants for Rural Areas and Tribal Transit Programs, Aging Cluster Federal Agency: U.S. Department of Transportation, U.S. Department of Health and Human Services ALN Number: 20.509 and 93.044, 93.045, 93.053 (Aging Cluster) Federal Award Number: 2201ALSTPH-00/2101ALOASS,2101ALALVAC/2101ALSSC6, 2101ALOACM/2201ALOAHD Compliance Requirement: Subrecipient Monitoring Criteria: 2 CFR 200.332 provides various requirements for subrecipient monitoring including the following: • 2 CFR 200.332(d) requires pass-through entities to “monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. • 2 CFR 200.332(f) requires pass-through entities to “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: Warren Averett tested 8 subrecipients in the Aging Cluster and noted that two were not monitored adequately during the award period and the Commission did not obtain single audit reports for any of the subrecipients tested. Warren Averett tested 3 subrecipients in ALN#20.509 and noted that the Commission did not obtain the single audit reports for any of these subrecipients. Cause: Although the Commission performed certain procedures required by 2 CFR 200.332, the policies and procedures do not contain adequate guidance to fully address the requirements. Effect: The lack of adequate policies and procedures can lead to noncompliance with federal statutes regulations and the provisions of grant agreements which could ultimately lead to disallowed costs for the major federal program. Repeat Finding: This is not a repeat finding. Recommendation: Warren Averett recommends that the Commission strengthen its documented policies and procedures regarding subrecipient monitoring. View of Responsible Officials: See Corrective Action Plan at the end of the report.
Finding Type - Material weakness relative to timely reporting of the schedule of expenditures of federal awards ("SEFA") and associated data collection form on reporting for single audits. 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. Context - In fiscal year 2022, the Organization had $1,631,922 in expenditures under various federal awards to report on the Schedule of Expenditures of Federal Awards ("SEFA"). The Organization did not have the single audit completed within the Uniform Guidance required timeframe. Cause/Effect - The Organization's controls were not adequate to ensure compliance with federal statutes, regulations, and Uniform Guidance requirements. Recommendation - We recommend the Organization strengthen internal controls and evaluate or monitor compliance with federal statutes, regulations, and the terms and conditions of their awards. In addition, we recommend the Organization ensures that SEFA is reviewed prior to providing it to the auditors. Finally, the Organization should consider incorporating the SEFA preparation within their checklist for the monthly closeout process.
Finding No.: 2022-005 Federal Agency: U.S. Department of the Interior AL Program: 15.875 Economic, Social, and Political Development of the Territories Federal Award No.: D22AF00029-00 Area: Subrecipient Monitoring Questioned Costs: $1,030,566 Criteria: In accordance with applicable subrecipient requirements (CFR §200.332), a pass-through entity (PTE) must: a. Ensure that the 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 PTE must provide the best information available to describe the Federal award and subaward. Required information includes: 1. Federal award identification: (i) Subrecipient’s name, (ii) Subrecipient’s unique entity identifier, (iii) Federal Award Identification Number (FAIN), (iv) Federal Award Date, (v) Subaward Period of Performance Start and End Date, (vi) Subaward Budget Period Start and End Date, (vii) Amount of Federal Funds Obligated by this action by the PTE to the subrecipient, (viii) Total Amount of Federal Funds Obligated to the subrecipient by the PTE including the current financial obligation, (ix) Total Amount of the Federal Award committed to the subrecipient by the PTE, (ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA), (x) Name of Federal awarding agency, PTE, and contact information for awarding official of the PTE, and (xi) Assistance Listings Number and Title; the PTE must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement. 2. All requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. b. 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, c. Verify that every subrecipient is audited as required by CFR Subpart F when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in CFR § 200.501, d. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the PTE's own records, and e. Consider taking enforcement action against noncompliant subrecipients as described in CFR §200.339. Condition: An amount of $1,030,566 (Doc #626) was passed through to Belau Submarine Cable Corporation (BSCC), a component unit of the Republic, for the submarine fiber optic cable project for the year ended September 30, 2022; however, there was lack of evidence to indicate that the above criteria was met. Cause: The Republic lacks internal control policies and procedures to identify subrecipient relationships and monitor subrecipients to ensure compliance with applicable subrecipient requirements. Effect: The Republic is in noncompliance with applicable subrecipient requirements and therefore $1,030,566 is questioned. Recommendation: The Republic should develop and implement internal control policy and procedures to identify subrecipient relationship and monitor activities of subrecipients to ensure compliance with applicable subrecipient requirements. Views of Responsible Officials: The Republic’s Corrective Action Plan does not indicate disagreement and provides planned corrective action.
OTHER, THE NVT DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE AUDIT WITHIN THE EARLIER OF 30 DAYS AFTER RECEIPT OF THE AUDIT REPORT, OR NINE MONTHS AFTER THE END OF THE AUDIT PERIOD. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATTIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE NVT MUST HAEV AN AUDIT PERFORMED AND SUBMITTED WITHIN 9 MONTHS OF YEAR END. NO QUESTIONED COSTS. MANAGEMENT DID NOT ENSURE THAT THE AUDITS WERE PERFORMED TIMELY. LATE REPORTING COULD JEOPARDIZE GRANT FUNDING. I RECOMMEND THAT THE COUNCIL ENSURE TIMELY AUDITS FOR FUTURE AUDITS. THIS FINDING WAS NOTED AS FINDING 2020-003 AND 2021-003.
Finding No. 2022-044 Federal Agency: U.S. Department of the Homeland Security AL Program: 97.036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) Federal Award No.: FEMA-4396-DR; FEMA-4234-DR, FEMA-4404-DR; FEMA-4511-DR Area: Subrecipient Monitoring Questioned Costs: $1,540,330 Criteria: In accordance with 2 CFR 200.332(e), a pass-through entity (PTE) must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The PTE is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a PTE must review financial and performance reports. Further, in accordance with 2 CFR 200.332(g), a PTE must verify that a subrecipient is audited as required by Subpart F 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: 1. Of eight subrecipients tested, aggregating $1,540,330, of a total population of $6,850,955, the following were noted: a. For eight (or 100%), evidence of CNMI’s review of financial and programmatic reports were not provided. b. For two or (25%) subrecipients, the CNMI did not perform appropriate review and follow up of the subrecipients’ audited financial statements for fiscal year 2022, dated April 30, 2024 and February 23, 2024. The subrecipients’ SEFA failed to include the federal awards it received from the CNMI. No questioned costs are presented as the amounts are questioned at Condition 1a. 2. No evidence was provided of procedures used to determine that subrecipients expending $750,000 or more in Federal awards have met the audit requirement of 2 CFR part 200, subpart F and that the required audits are completed within nine months of the end of the subrecipient’s audit period. In addition, we are aware that Project Strings 8812210010, 8812210015, and FG88120004 Single Audit Reports were due; however, the audits are still ongoing. Cause: The CNMI failed to enforce compliance with subrecipient monitoring requirements. Effect: The CNMI is in noncompliance with applicable subrecipient monitoring requirements and questioned costs of $1,540,330 result for Condition 1a. Recommendation: The CNMI should consider developing a tracking system to monitor compliance with applicable subrecipient monitoring requirements. Views of Responsible Officials: Conditions 1 and 2 - The Public Assistance Office agrees with this finding and acknowledges that, as the pass-through entity, we are responsible for monitoring subrecipients. Refer to CNMI’s Corrective Action Plan for additional information.
Finding 2022-002: Subrecipient Monitoring Federal Department: Americorps (Corporation for National and Community Service) Pass-through Agencies: Connecticut Office of Higher Education Illinois Department of Public Health Illinois Department of Human Services Indiana Department of Workforce Development Wisconsin National and Community Service Board Americorps State and National, Federal Assistance Listing Number 94.006 Criteria 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D - Post Federal Award Requirements Standards for Financial and Program Management, Section 200.332. Requirements for pass-through entities, requires that ?All pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F?Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in Section 200.208 Specific conditions. (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. (3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521 Management decision. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; and (2) Performing on-site reviews of the subrecipient's program operations; (3) Arranging for agreed-upon-procedures engagements as described in Section 200.425 Audit services. (f) Verify that every subrecipient is audited as required by Subpart F?Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501 Audit requirements. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. (h) Consider taking enforcement action against noncompliant subrecipients as described in Section 200.338 Remedies for noncompliance of this part and in program regulations.? Condition During the current audit period, we noted Public Allies did not perform adequate monitoring of its subrecipient as required by Federal regulations. Cause Based on discussions with management, this occurred due to staffing turnovers, which resulted in challenges and a disruption in the planned implementation and/or carrying out of the monitoring plan and risk assessment as well as collection of adequate documentation to meet requirements. Effect Failure to adequately communicate and monitor the activities and performance of a subrecipient could result in Federal awards being used for unauthorized purposes and Public Allies? inability to adequately perform risk assessments on its subrecipient(s). Questioned Costs None. Context During the current audit period, we noted 12 subrecipients were awarded funds. During our review of 3 subrecipients, we noted adequate documentation was not maintained to support both the financial and programmatic monitoring of these subrecipients. Specifically, we noted documentation was not maintained to support Public Allies? evaluation of each subrecipients risk of noncompliance. Also, while Public Allies did obtain a copy of the subrecipient?s Single Audit Report, we were not provided with any evidence of Public Allies? review of the report, including and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332d(3). Identification of Repeated Findings None. Recommendation We recommend Public Allies update its written procedures to document the monitoring of its subrecipients in accordance with 2 CFR 200.332. Also, adequate staff resources and training should be in place to oversee the process of completing the required subrecipient monitoring, including documentation of the evaluation of the subrecipient risk of noncompliance and review of the Single Audit report, as required by federal regulations. Views of Responsible Official and Planned Corrective Action Public Allies agree with the finding and recommendation. See Public Allies? Corrective Action Plan on pages 41-42.