Criteria: 2 CFR 200.332 provides the various requirements for subrecipient monitoring. 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.? The University has adopted a subrecipient monitoring policy which addresses the subrecipient monitoring requirements prescribed by 2 CFR 200.332 and includes a provision that the ?Office of Sponsored Projects (OSP) compiles an annual listing of all accounts with expenditures in sub-recipient account codes and requests audit reports from appropriate sub-recipients. The audit reports are reviewed by OSP and any exceptions are noted and reviewed with the sub-recipient. If findings of noncompliance are identified as a result of an audit, sub-recipients are required to provide copies of responses to auditors' reports and a plan for corrective action.? Condition: For one subrecipient the University did not obtain the single audit report and consequently, did not review for any applicable audit findings pertaining to the Federal award provided to the subrecipient. Context: The University had subrecipient agreements with two entities expected to have single audits. We selected one subrecipient for testing and noted that although the University performed the monitoring activities on the subrecipient during the year, the University did not obtain the single audit report for the entity. Cause: Although the University performed certain subrecipient monitoring procedures and has procedures in place to annually obtain and review single audit reports from applicable subrecipients, there was a lack of diligence in complying with the procedures. Effect: Failure to obtain and review the single audit reports of subrecipients, and consequently, not reviewing for any applicable audit findings pertaining to the Federal award provided to the subrecipient, could result in noncompliance with the subrecipient monitoring requirement. Questioned Costs: None Identification of a repeat finding: N/A Recommendations: We recommend the University follow their procedures for subrecipient monitoring to obtain and review single audit reports for subrecipients expected to obtain a single audit and review any applicable audit findings. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the Principal Investigators together to ensure that the required procedure for subrecipient monitoring is conducted and evidence of such procedure is maintained. The OSP staff will strengthen its policies and procedures so that the required subrecipient single audit report is obtained and reviewed periodically to confirm that the recipient is in compliance with all the applicable federal regulations.
Reference Number: 2022-010 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grant Assistance Listing Number: 14.228 Award Number and Year: B-20-DW-50-0001 (2020) B-20-DC-50-0001 (2020) B-21-DC-50-0001 (2021) Compliance Requirement: Subrecipient Monitoring Type of Finding Significant Deficiency in Internal Control Over Compliance, Other Matters Criteria or specific requirement: Compliance: 2 CFR ?200.332 - Requirements for Pass-Through Entities states, in part, that all pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F - Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (f) Verify that every subrecipient is audited as required by Subpart F - Audit Requirements of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501 Audit requirements. Control: Per 2 CFR Section 200.303(a), a non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The State of Vermont Agency of Commerce and Community Development was not able to provide support that it ensured its subrecipients were audited as required by 2 CFR Part 200 Subpart F ? Audit Requirements (Subpart F). Context: Exceptions were noted in three of eight subrecipients selected for testing: ? For three of eight subrecipients, the Agency was unable to provide support that it ensured the subrecipients were audited as required by Subpart F. Questioned costs: Undetermined. Cause: The Agency did not establish effective internal controls and procedures over subrecipient monitoring to ensure that it issued and monitored subawards in accordance with 2 CFR section 200.332. Effect: Failure to ensure subrecipients have obtained audits as required by Subpart F increases the risk that subrecipients may inappropriately spend and/or inaccurately track and report federal funds over multiple year periods, and these discrepancies may not be properly monitored, detected, or corrected on a timely basis. Questioned costs: Undetermined Recommendation: We recommend the Agency review and enhance internal controls and procedures to ensure that an evaluation of independent audits is performed. Views of responsible officials: Management agrees with the finding.
The Warren County Fiscal Court Failed To Implement Adequate Internal Controls Over Subrecipient Monitoring Federal Program: 21.027 COVID-19 - Coronavirus State And Local Fiscal Recovery Funds Award Number and Year: 1505-0271 2021 Name of Federal Agency and Pass-Thru Agency (if applicable): U.S. Department of the Treasury Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Amount of Questioned Costs: None Opinion Modification (if applicable): Yes, Qualified COVID Related: Yes The Warren County Fiscal Court failed to implement adequate internal controls over subrecipient monitoring. The fiscal court granted a subaward of Coronavirus State And Local Fiscal Recovery Funds to Live the Dream Development, Inc. in the amount of $1,000,000 for an affordable housing project. As a requirement of the subaward, the subrecipient is required to submit quarterly progress and financial reports to the fiscal court. The fiscal court did not receive any quarterly subrecipient progress or financial reports during the 2021-2022 fiscal year. Awards unspent as of December 31, 2024 are required to be returned to the Warren County Fiscal Court. The award of $1,000,000 was paid on February 14, 2022. Subrecipient reports were not submitted by the subrecipient for quarters ending on March 31, 2022 or June 30, 2022. This was caused by an oversight of the fiscal court. The county treasurer was unaware that reports needed to be submitted to the fiscal court even if none of the funds have been spent by the subrecipient. The treasurer was under the assumption that the project had not been started as of June 30, 2022. By not receiving adequate subrecipient monitoring documentation, the fiscal court is unable to document their supervision of the subaward to the agency to ensure requirements for the federal monies are being followed. Additionally, unallowable activities could go unnoticed due to the lack of oversight. In addition, the opinion was modified. 2 CFR 200.332 lists the requirements for pass-through entities. 2 CFR 220.332(d) requires all 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. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity.? Additionally, 2 CFR 200.501(a) states ?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 or program-specific audit conducted for that year in accordance with the provisions of this part.? This is not a repeat finding from the previous year.
2022-026 Oregon Housing and Community Services Department Implement program monitoring over client assistance payments to ensure compliance Federal Awarding Agency: U.S. Department of the Treasury Assistance Listing Number and Name: 21.023 Emergency Rental Assistance Program (COVID-19) Federal Award Numbers and Years: ERA 1, 2021; ERA 2, 2021 (COVID-19) Compliance Requirement: Activities Allowed or Unallowed; Eligibility Type of Finding: Material Weakness; Material Noncompliance Prior Year Finding: N/A Questioned Costs: $21,624 (known); $11,067,350 (likely) (COVID-19) Criteria: 2 CFR 200.332(d); 2 CFR 200.501(g) Department management is responsible for monitoring the activities of subrecipients to ensure subawards are used for authorized purposes and are compliant with federal requirements. Additionally, department management is responsible for ensuring compliance when a contractor is responsible for program compliance or the contractor?s records must be reviewed to determine program compliance. The department provided $140 million and $46 million of phase one program funds to community action agencies (subrecipients) and a third-party vendor (contractor) to provide program delivery, respectively; and $132 million phase two program funds to only the contractor. Program delivery included determining client eligibility and making payments for direct client assistance for rent, utilities, internet, and other housing related costs. During implementation of the program, the department provided program manuals to the subrecipients and contractor. Due to the department?s limited staff, they focused on updating policies and procedures to address systemic issues identified; however, if a particularly challenging application required the department?s review, they were available to provide direct assistance. The department did not implement any predefined, systemic program monitoring of the subrecipients or contractor to ensure direct client assistance payments were paid to only eligible clients for only allowable and supported amounts. Therefore, auditors performed additional procedures at the subrecipient and contractor level to determine whether direct client assistance payments were paid to eligible clients for allowable activities. We tested a total of 62 randomly selected direct client assistance payments at 16 subrecipients totaling $183,515, and found the following: ? One subrecipient did not respond to audit requests for documentation, resulting in an inability to test one transaction in the amount of $360. ? One subrecipient did not obtain documentation to support that there was a lease agreement in place, resulting in questioned costs of $5,775. When extrapolated to the total population, these errors result in over $2.3 million in likely questioned costs. We tested 61 randomly selected contractor direct client assistance payments totaling $374,274, and found the following: ? One payment where an incorrect landlord was paid in the amount of $2,700. Attempts to recover the funds have been unsuccessful as of the date of the finding. ? Two payments where the rental amount was doubled, resulting in overpayments totaling $5,910. ? Seven payments where amounts already paid were not accurately reflected in the calculation of assistance provided, resulting in overpayments totaling $4,191. ? Three payments where amounts did not agree to supporting documentation, resulting in overpayments of $2,181. ? Three payments where there was insufficient documentation for amounts paid, resulting in overpayments of $432. ? One payment where costs were paid for the same household on alternate applications, resulting in an overpayment of $73. When extrapolated to the total population, these errors result in over $8.7 million in likely questioned costs. We recommend department management implement predefined, systemic program monitoring to ensure the subrecipients and contractor are administering program funds in accordance with program requirements.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
2022 ? 007 (Previously 2021-003) Subrecipient Monitoring (Significant Deficiency and Noncompliance) Federal Agency: U.S. Department of Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Pub. L. No. 117-2-2021 Award Period: 5/10/2021 - 12/31/2026 Type of Finding: ? Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: According to ? 200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to ? 200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through 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. ? 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. ? Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. ? Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. According to the City's subrecipient monitoring policies and procedures, monitoring of subrecipients shall be conducted as often as may be required at the discretion of the Community Development Division or at least once per program year. An annual Risk Assessment will be completed to determine a ranking for the activity. The Risk Assessment ranking score will determine whether a monitoring review will occur. Condition: During our testing, it was noted that the City did not follow federal subrecipient monitoring and management regulation nor its subrecipient monitoring policies and procedures. Questioned costs: None 2022 ? 007 (Previously 2021-003) Subrecipient Monitoring (Significant Deficiency and Noncompliance) (Continued) Context: During our testing, we noted the following exceptions: ? For 2 of 4 subrecipients, the City did not utilize the risk assessment tool specific to ARPA which does have a different risk assessment ranking score determining the monitoring of the subrecipient. The City did, however, perform a monitoring visit for the subrecipients. ? For 1 of 4 subrecipients, the City did not utilize the risk assessment tool specific to ARPA. The City utilized the AGA Risk Assessment Monitoring Tool. We noted the following exceptions. ? According to the Introduction of the AGA Risk Assessment Monitoring Tool, while the risk assessment monitoring tool may be useful in supplementing existing tools, it is not intended to replace any risk assessment tools that may already be in use by monitoring agencies. Further, the City omitted the Programmatic Assessment of the AGA Risk Assessment Monitoring Tool. ? According to the Introduction of the AGA Risk Assessment Monitoring Tool, in using the risk assessment tool, monitoring agencies are encouraged to develop applicable risk factors to evaluate programmatic compliance risk and should use professional judgment in developing a weighted scoring system for each component of the assessment. The City did not develop a weighted scoring system for each component of the assessment. ? No evidence of approval of the AGA Risk Assessment Monitoring Tool. ? In the Monitoring/Audit Assessment section of the AGA Risk Assessment Monitoring Tool, the City marked all N/A based on a response of the subrecipient has not needed to complete a single audit in the past. However, the subrecipient did have a single audit for the fiscal year end date of 12/31/2020 with the Federal Audit Clearinghouse receiving the audit report on 5/27/2021. No review of the single audit by the City. Management?s Progress for Repeat Findings: The City Controller reviewed the listing of subrecipient risk assessments for 2022 and the listing was determined to be complete. The City will update the subrecipient monitoring policies and procedures ad provide training to the departments. Cause: The City failed to follow federal subrecipient monitoring and management regulation nor its subrecipient monitoring policies and procedures. Repeat Finding: 2021-003 Effect: The auditor noted instances of noncompliance. Noncompliance results in subrecipients' noncompliance with federal statutes, regulations, and the terms and conditions of the subaward. Recommendation: We recommend the City design controls to ensure compliance with federal subrecipient monitoring and management regulation and its subrecipient monitoring policies and procedures. Management Response: Management agrees with the finding. The City will develop standard City-wide subrecipient management policies and procedures including risk assessment and monitoring tools. Additionally, any federal program with two or more City departments managing subrecipients will use the same subrecipient tools to ensure consistency. Timeline and Responsible Position: June 2023 ? City Controller/DFAS Deputy Director
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 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. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1. Reviewing of financial and performance reports as required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: None noted. Context/Sampling: We selected 100% of the County?s subrecipients of the program. $6,177,719 was paid to the subrecipient during the fiscal year. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Subrecipient Monitoring 2022-007 GENERAL INFORMATION: Grant Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Number: Assistance Listing #: 21.027 Federal Agency: Department of the Treasury CONDITION: We noted during our audit that the Randolph County Commission failed to properly monitor subrecipients. Specifically, there was no assurance that the allocated funds sent were expensed by the subrecipients. CRITERIA: 'Proper internal control over federal awards passed to subrecipients requires the establishment and maintenance of an effective system to provide reasonable assurance that the subrecipient is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. 2 CFR Part 200.332 states, in part, that: "(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes:(1) Federal award identification. (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x)Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi)Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii)Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv)Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. (4) (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with ? 200.405(d). (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F 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).... (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ?200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward.... (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501. (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." QUESTIONED COSTS: $163,617 CONTEXT: Disbursements totaling $163,617 were made to subrecipients without activities being monitored to ensure expenditures of the subaward were being used for authorized purposes and in accordance with the grant guidelines. CAUSE: The Randolph County Commission did not have procedures in place to ensure subrecipient monitoring requirements were performed. EFFECT: Failure to properly monitor subrecipients increases the likelihood of errors or irregularities not being prevented or detected in a timely manner. Additionally, the risk of unallowable activities and unallowable costs is significantly increased. Management failed to comply with all applicable, material compliance requirements of the grant agreement. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2021-002 RECOMMENDATION: The Randolph County Commission is directed to review these regulations and comply with the provisions set forth therein. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: We will comply and monitor subrecipient spending going forward.
Criteria: Single Audits under 2 CFR Part 200 Subpart F 200.501? Audit Requirements are required to be submitted through the Federal Clearinghouse nine months from the recipient?s year end. Condition: For the third year in a row the County has not been able to begin the audit early enough to meet the nine-month submission deadline. Cause and Effect: The County has been unable to close the financial records and submit the required information to the auditors in a timely manner, resulting in noncompliance. Repeat Finding: No Recommendation: We recommend that the County submit the required information to the auditors in a timely manner in an effort to meet this deadline. To achieve this goal, it may require the County to either increase staffing levels or hire a consultant.
Criteria: Single Audits under 2 CFR Part 200 Subpart F 200.501? Audit Requirements are required to be submitted through the Federal Clearinghouse nine months from the recipient?s year end. Condition: For the third year in a row the County has not been able to begin the audit early enough to meet the nine-month submission deadline. Cause and Effect: The County has been unable to close the financial records and submit the required information to the auditors in a timely manner, resulting in noncompliance. Repeat Finding: No Recommendation: We recommend that the County submit the required information to the auditors in a timely manner in an effort to meet this deadline. To achieve this goal, it may require the County to either increase staffing levels or hire a consultant.
Criteria: Single Audits under 2 CFR Part 200 Subpart F 200.501? Audit Requirements are required to be submitted through the Federal Clearinghouse nine months from the recipient?s year end. Condition: For the third year in a row the County has not been able to begin the audit early enough to meet the nine-month submission deadline. Cause and Effect: The County has been unable to close the financial records and submit the required information to the auditors in a timely manner, resulting in noncompliance. Repeat Finding: No Recommendation: We recommend that the County submit the required information to the auditors in a timely manner in an effort to meet this deadline. To achieve this goal, it may require the County to either increase staffing levels or hire a consultant.