FINDING 2024-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Subrecipient Monitoring Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): SLFRP1096 Compliance Requirement: Subrecipient Monitoring Audit Finding: Material Weakness INDIANA STATE BOARD OF ACCOUNTS 19 CITY OF ANDERSON SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Condition and Context Subrecipients associated with the City's Non-profit, Affordable Housing, and Homeless Initiatives activities funded by the COVID-19 - Coronavirus State and Local Fiscal Recovery Funds were required to submit reports on program activities either quarterly or monthly. The City did not have adequate internal controls in place designed to ensure that these reports were reviewed. Responsibility for reviewing these reports rested primarily with one employee. For two of three subrecipients tested, we were not able to determine that there was a second employee involved that would ensure that the reports submitted by the subrecipients were reviewed by the City. The lack of internal controls was a systemic issue throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.332 states: "All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and include the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward notification. 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; INDIANA STATE BOARD OF ACCOUNTS 20 CITY OF ANDERSON SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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 passthrough entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the passthrough 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 passthrough 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. (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). INDIANA STATE BOARD OF ACCOUNTS 21 CITY OF ANDERSON SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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). (c) Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. (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. INDIANA STATE BOARD OF ACCOUNTS 22 CITY OF ANDERSON SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (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. (e) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in paragraph (b) of this section), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program related matters; and (2) Performing on-site reviews of the subrecipient's program operations. (3) Arranging for agreed-upon-procedures engagements as described in § 200.425. (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. (h) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations." Cause A system of internal controls to include oversite and review of the quarterly or monthly reports prepared by the subrecipients was not in place. One individual was primarily responsible for reviewing the subrecipient reports. Effect Not having procedures in place for oversite and review of the monitoring reports could lead to noncompliance with the requirements for subrecipient monitoring. Noncompliance with the provisions of federal statutes, regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the City. INDIANA STATE BOARD OF ACCOUNTS 23 CITY OF ANDERSON SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City establish a proper system of internal controls to include oversite and review to ensure that the subrecipient report reviews are reviewed/approved by a second party. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Noncompliance with Subrecipient Monitoring Requirements and Material Weakness in Internal Control over Subrecipient Monitoring Assistance Listing Number: 21.027 Name of Federal Program or Cluster: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Name of Pass-Through Entities: State of Wisconsin Department of Administration Subrecipient Monitoring 2 CFR§200.332 requirements for pass-through entities: The Code of Federal Regulations (CFR) Section 200.332(e) requires a pass-through entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) Resolve audit findings specifically related to the subaward. 2 CFR§200.303 requires the Organization to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). The organization did not perform subrecipient monitoring procedures as listed in the criteria above for the subrecipient of the COVID-19: Coronavirus State and Local Fiscal Recovery Funds. In addition, the Organization’s internal controls over subrecipient monitoring did not prevent or detect noncompliance with subrecipient monitoring requirements. The Organization did, however, confirm with SAM.gov that the subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal Funds; included the required information in the subaward agreement, and performed the required risk assessment. The Organization has policies and procedures related to subrecipient monitoring in its fiscal procedures manual. However, management did not monitor to ensure that the requirements listed in its policies and procedures manual as well as the Uniform Guidance are being followed. Failure to adequately monitor subrecipients may result in the subrecipient not properly administering the federal program in accordance with laws, regulations, and the grant agreement. Recommendation: We recommend that Organization management monitor their compliance with their subrecipient monitoring procedures to ensure that the required subrecipient monitoring is occurring. No WRTP has reviewed the organization’s fiscal policy manual including all subsections regarding monitoring responsibilities. Additional training has been provided and completed by management and staff. Management has reviewed all monitoring with the subrecipient in good faith efforts.
Noncompliance with Subrecipient Monitoring Requirements and Material Weakness in Internal Control over Subrecipient Monitoring Assistance Listing Number: 21.027 Name of Federal Program or Cluster: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Name of Pass-Through Entities: State of Wisconsin Department of Administration Subrecipient Monitoring 2 CFR§200.332 requirements for pass-through entities: The Code of Federal Regulations (CFR) Section 200.332(e) requires a pass-through entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) Resolve audit findings specifically related to the subaward. 2 CFR§200.303 requires the Organization to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). The organization did not perform subrecipient monitoring procedures as listed in the criteria above for the subrecipient of the COVID-19: Coronavirus State and Local Fiscal Recovery Funds. In addition, the Organization’s internal controls over subrecipient monitoring did not prevent or detect noncompliance with subrecipient monitoring requirements. The Organization did, however, confirm with SAM.gov that the subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal Funds; included the required information in the subaward agreement, and performed the required risk assessment. The Organization has policies and procedures related to subrecipient monitoring in its fiscal procedures manual. However, management did not monitor to ensure that the requirements listed in its policies and procedures manual as well as the Uniform Guidance are being followed. Failure to adequately monitor subrecipients may result in the subrecipient not properly administering the federal program in accordance with laws, regulations, and the grant agreement. Recommendation: We recommend that Organization management monitor their compliance with their subrecipient monitoring procedures to ensure that the required subrecipient monitoring is occurring. No WRTP has reviewed the organization’s fiscal policy manual including all subsections regarding monitoring responsibilities. Additional training has been provided and completed by management and staff. Management has reviewed all monitoring with the subrecipient in good faith efforts.
Noncompliance with Subrecipient Monitoring Requirements and Material Weakness in Internal Control over Subrecipient Monitoring Assistance Listing Number: 21.027 Name of Federal Program or Cluster: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Name of Pass-Through Entities: State of Wisconsin Department of Administration Subrecipient Monitoring 2 CFR§200.332 requirements for pass-through entities: The Code of Federal Regulations (CFR) Section 200.332(e) requires a pass-through entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: (1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521. (4) Resolve audit findings specifically related to the subaward. 2 CFR§200.303 requires the Organization to establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the 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). The organization did not perform subrecipient monitoring procedures as listed in the criteria above for the subrecipient of the COVID-19: Coronavirus State and Local Fiscal Recovery Funds. In addition, the Organization’s internal controls over subrecipient monitoring did not prevent or detect noncompliance with subrecipient monitoring requirements. The Organization did, however, confirm with SAM.gov that the subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal Funds; included the required information in the subaward agreement, and performed the required risk assessment. The Organization has policies and procedures related to subrecipient monitoring in its fiscal procedures manual. However, management did not monitor to ensure that the requirements listed in its policies and procedures manual as well as the Uniform Guidance are being followed. Failure to adequately monitor subrecipients may result in the subrecipient not properly administering the federal program in accordance with laws, regulations, and the grant agreement. Recommendation: We recommend that Organization management monitor their compliance with their subrecipient monitoring procedures to ensure that the required subrecipient monitoring is occurring. No WRTP has reviewed the organization’s fiscal policy manual including all subsections regarding monitoring responsibilities. Additional training has been provided and completed by management and staff. Management has reviewed all monitoring with the subrecipient in good faith efforts.
2024-001: Subrecipient Monitoring Criteria: The Code of Federal Regulations 2 CFR 200.332 states that all pass-through entities (PTE) must: Identify the Award and Applicable Requirements - Clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2)all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Evaluate Risk - Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). Monitor - Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: (1) Reviewing financial and programmatic (performance and special reports) required by the PTE. (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 PTE 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 PTE as required by 2 CFR section 200.521. Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Cause: The Organization has not implemented policies or procedures, to the degree necessary, to ensure that federal award monitoring compliance requirements are being met. Effect: The Organization did not perform adequate monitoring procedures on the subrecipients. Without communication of required information, subrecipients may overspend award amounts or incur unallowable expenses towards the grant. Questioned Costs: N/A Statistical Sampling: Statistical sampling was not used in making sample selections. Recommendation: We recommend that management of the Organization implement policies, procedures, and internal controls to evaluate the subrecipient risk of noncompliance to ensure subrecipients are being appropriately monitored in compliance with federal regulations. Views of Responsible Officials: Management agrees with this finding and their response is included in the corrective action plan.
Finding No. 2024-002 – Subrecipient Monitoring | Identification of the Program: | Program Name: Research and Development Cluster: Basic Scientific Research, Department of Defense Awarding Office, 12.431; NSF Technology, Innovation and Partnerships, National Science Foundation, 47.084 | Criteria or Specific Requirements (Including Statutory, Regulatory, or Other Citations): 2 CFR 200.303 requires that a non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” According to page 3-M-1 of the 2024 OMB Compliance Supplement, management is responsible for monitoring activities designed to evaluate subrecipient risk as required by the terms and conditions of the award. Such activities include: reviewing financial reports; following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits, on-site reviews, and other; issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. | Section III— Federal Award Findings and Questioned Costs (continued) | Condition: During our testing of 2024 subrecipient monitoring activities, we selected five subrecipients for testing noting that there was no evidence of management’s evaluation of each subrecipient or management’s review of the specific monitoring procedures performed. Through inquiry, management acknowledged that they complete an evaluation form for each subrecipient prior to contracting with the subrecipient although an evaluation of the risk of the subrecipient is not included on the form. Management also informed us that they review all expenditures and related supporting documentation provided by the subrecipient prior to paying their invoices, although evidence of performing such a review is not documented. | Cause: Internal controls over the review and approval of the subrecipient monitoring were not effective. | Effect or Potential Effect: This could result in granting subawards to and paying subrecipients who are of higher risk for compliance and/or subrecipients who have not been properly monitored to ensure they are complying with the grant terms. | Questioned Costs: None. | Context: As the sample size is small, we selected 5 subrecipients for testing out of a total of 5 subrecipients. | Identification as a Repeat Finding: N/A – This is a first year Uniform Guidance audit.
Subrecipient Monitoring Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 002 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, “the recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Section 200.332. Requirements for pass-through entities, requires that “A pass-through entity must: (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have 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 any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency)... (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must:(1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521.(4)Resolve audit findings specifically related to the subaward…. (g)Verify that a subrecipient is audited as required by subpart F of this part. (h) Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations. CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its subrecipient monitoring requirements as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding was an inadequate understanding of sub-recipient monitoring policies and best practices. While the Department believed at the time that they were in compliance with the applicable monitoring requirements, they now recognize that their efforts did not fully meet the necessary standards. EFFECT Failure to adequately perform and document the risk assessments on its subrecipient(s) could result in the inadequate monitoring of the activities and performance of a subrecipient. Also, this could result in Federal awards being used by the subrecipient for unauthorized purposes. QUESTIONED COSTS None. CONTEXT During our review of two (2) subrecipients (of a population of 4 subrecipients), we noted the following: For both subrecipients, we noted documentation was not maintained to support SAO’s evaluation of the subrecipients’ risk of noncompliance and the frequency of monitoring to be conducted by SAO based on the assessed risk. We also noted for both subrecipients, no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including SAO’s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332e(3). The SAO utilized a “Subrecipient Monitoring Checklist” (Checklist) to conduct and document its monitoring of subrecipients. Based on review, we noted the Checklist does not include evidence of who completed the monitoring, the date the actual monitoring was performed nor the subrecipient personnel with whom the monitoring results were discussed during the site visit. Also, the Checklist appears to be inaccurately completed. Specifically, we noted the Checklist noted that the results include expected corrective actions and dates for resolution. However, there was no finding or issues noted in the formal letter submitted to the subrecipient(s) after the site visit(s). IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend SAO implement procedures to ensure adequate documentation is maintained to support the evaluation of each subrecipient’s risk of noncompliance and review of the Single audit report, as required by Federal regulations. Also, we suggest that the Checklist be accurately prepared and updated to include evidence of who completed the monitoring, the date the actual monitoring was performed, and the subrecipient personnel with whom the monitoring results were discussed during the site visit. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on pages 38-39.
Subrecipient Monitoring Federal Department – U.S. Department of Justice Pass-through Illinois Criminal Justice Information Authority Federal Award Identification Number and Year: 15JOVW-21-GG-00543-STOP and 2021 15JOVW-22-GG-00422-STOP and 2022 Violence Against Women Formula Grants, Federal Assistance Listing #16.588 County Department – State’s Attorney Office Finding 2024 – 002 CRITERIA 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D—Post Federal Award Requirements Standards for Financial and Program Management, Section 200.303 Internal controls states, “the recipient and subrecipient must: (a) Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Section 200.332. Requirements for pass-through entities, requires that “A pass-through entity must: (c) Evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider the following: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have 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 any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency)... (e) Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must:(1) Review financial and performance reports. (2) Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. (3) Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521.(4)Resolve audit findings specifically related to the subaward…. (g)Verify that a subrecipient is audited as required by subpart F of this part. (h) Consider whether the results of a subrecipient's audit, site visits, or other monitoring necessitate adjustments to the pass-through entity's records. (i) Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 and in program regulations. CONDITION During the current audit period, the Cook County State’s Attorney Office (SAO) did not adequately comply with its subrecipient monitoring requirements as required by Federal regulations. CAUSE Based on discussions with management, the cause of this finding was an inadequate understanding of sub-recipient monitoring policies and best practices. While the Department believed at the time that they were in compliance with the applicable monitoring requirements, they now recognize that their efforts did not fully meet the necessary standards. EFFECT Failure to adequately perform and document the risk assessments on its subrecipient(s) could result in the inadequate monitoring of the activities and performance of a subrecipient. Also, this could result in Federal awards being used by the subrecipient for unauthorized purposes. QUESTIONED COSTS None. CONTEXT During our review of two (2) subrecipients (of a population of 4 subrecipients), we noted the following: For both subrecipients, we noted documentation was not maintained to support SAO’s evaluation of the subrecipients’ risk of noncompliance and the frequency of monitoring to be conducted by SAO based on the assessed risk. We also noted for both subrecipients, no documentation was provided to verify whether the subrecipients were required to have a Single Audit conducted, including SAO’s review of the report, and if applicable, issuance of a management decision on audit findings noted as required by 2 CFR 200.332e(3). The SAO utilized a “Subrecipient Monitoring Checklist” (Checklist) to conduct and document its monitoring of subrecipients. Based on review, we noted the Checklist does not include evidence of who completed the monitoring, the date the actual monitoring was performed nor the subrecipient personnel with whom the monitoring results were discussed during the site visit. Also, the Checklist appears to be inaccurately completed. Specifically, we noted the Checklist noted that the results include expected corrective actions and dates for resolution. However, there was no finding or issues noted in the formal letter submitted to the subrecipient(s) after the site visit(s). IDENTIFICATION OF REPEATED FINDINGS None. RECOMMENDATION We recommend SAO implement procedures to ensure adequate documentation is maintained to support the evaluation of each subrecipient’s risk of noncompliance and review of the Single audit report, as required by Federal regulations. Also, we suggest that the Checklist be accurately prepared and updated to include evidence of who completed the monitoring, the date the actual monitoring was performed, and the subrecipient personnel with whom the monitoring results were discussed during the site visit. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS The County agrees with the finding and recommendation. The County’s corrective action plan is on pages 38-39.
FINDING 2024-028 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition LEO, MSF, and EGLE did not properly monitor their subrecipients to ensure they complied with the Uniform Guidance. We noted: a. LEO and MSF did not have a process to identify or document if their subrecipients required a single audit. Therefore, LEO and MSF did not monitor these subrecipients to ensure the status or submission of their single audit reports and did not determine whether a management decision letter was needed. b. EGLE did not identify or document if its subrecipients required a single audit for 8 (67%) of 12 sampled subrecipients. We reviewed the federal audit clearinghouse (FAC) and noted 2 of the 8 subrecipients had single audit reports submitted to the FAC in fiscal year 2024. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521(d) requires the pass-through entity to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause For part a., LEO indicated because of limited staff resources it did not have a process in place to monitor subrecipient single audits. MSF indicated it believes its current process was sufficient because it requires the subrecipients to notify MSF upon completion of their single audits. For part b., EGLE informed us due to an increase in subrecipients and division of responsibilities, not all CSLFRF subrecipients were tracked for single audits. Effect LEO, MSF, and EGLE limited the State's assurance their subrecipients complied with grant requirements and implemented corrective actions for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to their records. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend LEO, MSF, and EGLE properly monitor their subrecipients to ensure they comply with the Uniform Guidance. Management Views For part a., LEO agrees with the finding. All three of MSF's subrecipient awards for the fiscal year were sampled totaling approximately $274,000 (0.3 percent of the total award). While MSF agrees with the finding that it did not have a written process to verify single audit compliance, management believes that MSF's risk assessment of subrecipients adequately determined that single audit verification was not required for two of its subrecipients since, based on all anticipated federal awards for the subrecipient, it was not expected that they would reach the expenditure threshold (2 CFR 200.332(f)). The third annually files a single audit, was expected to file a single audit, and did file a single audit. For part b., EGLE agrees with the finding. Auditor's Comments to Management Views Regarding part a., MSF acknowledges it does not have a process to identify or document its review of subrecipient single audit reports. MSF did not provide documentation to support the award period or the amount of the subaward to these three subrecipients. Regardless of the amount of the subaward, federal regulation 2 CFR 200.501 indicates the $750,000 threshold is based on the subrecipient's total federal expenditures for all federal programs during its fiscal year and not based on a specific program's subaward amounts or expenditures. Also, MSF did not review the single audit report submitted to the FAC and determine if it was necessary to issue a management decision letter for audit findings affecting the subawards it issued to the subrecipient. Therefore, the finding stands as written.
Finding Number: 2024-008 Prior Year Finding Number: 2023-015 Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Year: 10/01/2021 – 09/20/2024 Government Department/Agency: Office of the Deputy Mayor for Public Safety and Justice (DMPSJ); Office of Neighborhood Safety and Engagement (ONSE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the Uniform Guidance in 2 CFR Section 200.331(a) Requirements for Pass-Through Entities requires that pass-through entities must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information outlined in the section noted above, pre-award assessment, indirect cost rated for the award, assistance listing number, finding and award follow-up and other pertinent actions. In accordance with the Uniform Guidance in 2 CFR Section 200.332 Requirements for Pass-Through Entities requires that pass-through entities Verify that the subrecipient is not excluded or disqualified in accordance with Section 180.300. Verification methods are provided in Section 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. In accordance with the Uniform Guidance in 2 CFR Section 200.332(e) Requirements for Pass-Through Entities requires that pass-through entities must: Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: • Review financial and performance reports • Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. • Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521. • Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section Section 200.513(a)(4)(viii). 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. Condition – The program’s documented subrecipient monitoring requirements includes risk assessments, monitoring of subrecipients and the submission and review of monthly financial and performance reports. During our testing of the subrecipient’s compliance requirements, we noted the following issues: • Our testing of the program’s subrecipient monitoring requirements includes submission and review of monthly financial and performance reports. We noted for one (1) out of 17 samples, the subrecipient failed to submit their monthly financial and performance reports. • For one (1) out of 17 samples, the agency had no evidence to support it had performed the mandatory follow up on reported audit findings in the subrecipient’s audit report for the Corrective Action taken by the subrecipient to remediate the finding. • For one (1) out of 17 samples, the agency had no evidence that a debarment check was performed before the contract was entered into. The agency’s documented policies and the procurement procedures mandate a debarment check before entering into new contracts. Questioned Costs – Not determinable. Context – This is a condition identified per review of various District agencies’ compliance with specified monitoring requirements on the program’s subrecipients using a statistically valid sample. Effect – Subrecipients may not be properly monitored, which may result in subawards being used for unauthorized purposes in violation of the terms and conditions of the subawards or that the subaward performance goals were not achieved. Cause – There is lack of sufficient documentary evidence to support that the controls are operating as designed related to subrecipient monitoring compliance. Recommendation – We recommend that the agencies maintain sufficient documentation to evidence its internal controls over the risk assessment and monitoring of subrecipients. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – While DMPSJ doesn’t agree that it is out of compliance, DMPSJ will ensure documentation is maintained regarding its oversight of grant management. ONSE acknowledges and accepts the finding that the subrecipient failed to submit their monthly and performance reports. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section. BDO’s Response – We have reviewed management’s response and our finding remains as indicated.
FINDING 2024-028 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027, Subrecipient Monitoring - Subrecipient Audits See Schedule of Findings and Questioned Costs for chart/table. Condition LEO, MSF, and EGLE did not properly monitor their subrecipients to ensure they complied with the Uniform Guidance. We noted: a. LEO and MSF did not have a process to identify or document if their subrecipients required a single audit. Therefore, LEO and MSF did not monitor these subrecipients to ensure the status or submission of their single audit reports and did not determine whether a management decision letter was needed. b. EGLE did not identify or document if its subrecipients required a single audit for 8 (67%) of 12 sampled subrecipients. We reviewed the federal audit clearinghouse (FAC) and noted 2 of the 8 subrecipients had single audit reports submitted to the FAC in fiscal year 2024. Criteria Federal regulation 2 CFR 200.501 requires nonfederal entities who expend $750,000 or more in federal awards during their fiscal year to obtain a single audit for that fiscal year. Also, federal regulation 2 CFR 200.332(f) requires the pass-through entity to verify these subrecipients are audited as required by Subpart F of the Uniform Guidance, Audit Requirements, when it is expected the subrecipient's federal awards expended during the respective fiscal year equaled or exceeded the $750,000 threshold. In addition, federal regulation 2 CFR 200.521(d) requires the pass-through entity to issue a management decision letter on the appropriateness of all audit findings related to its federal awards and the subrecipient's corrective action plan within six months of acceptance by the FAC. Cause For part a., LEO indicated because of limited staff resources it did not have a process in place to monitor subrecipient single audits. MSF indicated it believes its current process was sufficient because it requires the subrecipients to notify MSF upon completion of their single audits. For part b., EGLE informed us due to an increase in subrecipients and division of responsibilities, not all CSLFRF subrecipients were tracked for single audits. Effect LEO, MSF, and EGLE limited the State's assurance their subrecipients complied with grant requirements and implemented corrective actions for audit findings to prevent future sanctions or disallowed costs, which could necessitate adjustments to their records. The federal grantor agency could issue sanctions or disallowances related to noncompliance. Known Questioned Costs None. Recommendation We recommend LEO, MSF, and EGLE properly monitor their subrecipients to ensure they comply with the Uniform Guidance. Management Views For part a., LEO agrees with the finding. All three of MSF's subrecipient awards for the fiscal year were sampled totaling approximately $274,000 (0.3 percent of the total award). While MSF agrees with the finding that it did not have a written process to verify single audit compliance, management believes that MSF's risk assessment of subrecipients adequately determined that single audit verification was not required for two of its subrecipients since, based on all anticipated federal awards for the subrecipient, it was not expected that they would reach the expenditure threshold (2 CFR 200.332(f)). The third annually files a single audit, was expected to file a single audit, and did file a single audit. For part b., EGLE agrees with the finding. Auditor's Comments to Management Views Regarding part a., MSF acknowledges it does not have a process to identify or document its review of subrecipient single audit reports. MSF did not provide documentation to support the award period or the amount of the subaward to these three subrecipients. Regardless of the amount of the subaward, federal regulation 2 CFR 200.501 indicates the $750,000 threshold is based on the subrecipient's total federal expenditures for all federal programs during its fiscal year and not based on a specific program's subaward amounts or expenditures. Also, MSF did not review the single audit report submitted to the FAC and determine if it was necessary to issue a management decision letter for audit findings affecting the subawards it issued to the subrecipient. Therefore, the finding stands as written.
Finding Number: 2024-008 Prior Year Finding Number: 2023-015 Compliance Requirement: Subrecipient Monitoring Program: U.S. Department of the Treasury COVID-19 – Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award #: N/A Award Year: 10/01/2021 – 09/20/2024 Government Department/Agency: Office of the Deputy Mayor for Public Safety and Justice (DMPSJ); Office of Neighborhood Safety and Engagement (ONSE) Criteria - The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities receiving Federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statues, regulations, and the terms and conditions of the Federal award. In accordance with the Uniform Guidance in 2 CFR Section 200.331(a) Requirements for Pass-Through Entities requires that pass-through entities must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information outlined in the section noted above, pre-award assessment, indirect cost rated for the award, assistance listing number, finding and award follow-up and other pertinent actions. In accordance with the Uniform Guidance in 2 CFR Section 200.332 Requirements for Pass-Through Entities requires that pass-through entities Verify that the subrecipient is not excluded or disqualified in accordance with Section 180.300. Verification methods are provided in Section 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended, debarred, or otherwise excluded from receiving Federal funds. In accordance with the Uniform Guidance in 2 CFR Section 200.332(e) Requirements for Pass-Through Entities requires that pass-through entities must: Monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must: • Review financial and performance reports • Ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward. Significant developments include Single Audit findings related to the subaward, other audit findings, site visits, and written notifications from a subrecipient of adverse conditions which will impact their ability to meet the milestones or the objectives of a subaward. When significant developments negatively impact the subaward, a subrecipient must provide the pass-through entity with information on their plan for corrective action and any assistance needed to resolve the situation. • Issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by Section 200.521. • Resolve audit findings specifically related to the subaward. However, the pass-through entity is not responsible for resolving cross-cutting audit findings that apply to the subaward and other Federal awards or subawards. If a subrecipient has a current Single Audit report and has not been excluded from receiving Federal funding (meaning, has not been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant agency for audit or oversight agency for audit to perform audit follow-up and make management decisions related to cross-cutting audit findings in accordance with section Section 200.513(a)(4)(viii). 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. Condition – The program’s documented subrecipient monitoring requirements includes risk assessments, monitoring of subrecipients and the submission and review of monthly financial and performance reports. During our testing of the subrecipient’s compliance requirements, we noted the following issues: • Our testing of the program’s subrecipient monitoring requirements includes submission and review of monthly financial and performance reports. We noted for one (1) out of 17 samples, the subrecipient failed to submit their monthly financial and performance reports. • For one (1) out of 17 samples, the agency had no evidence to support it had performed the mandatory follow up on reported audit findings in the subrecipient’s audit report for the Corrective Action taken by the subrecipient to remediate the finding. • For one (1) out of 17 samples, the agency had no evidence that a debarment check was performed before the contract was entered into. The agency’s documented policies and the procurement procedures mandate a debarment check before entering into new contracts. Questioned Costs – Not determinable. Context – This is a condition identified per review of various District agencies’ compliance with specified monitoring requirements on the program’s subrecipients using a statistically valid sample. Effect – Subrecipients may not be properly monitored, which may result in subawards being used for unauthorized purposes in violation of the terms and conditions of the subawards or that the subaward performance goals were not achieved. Cause – There is lack of sufficient documentary evidence to support that the controls are operating as designed related to subrecipient monitoring compliance. Recommendation – We recommend that the agencies maintain sufficient documentation to evidence its internal controls over the risk assessment and monitoring of subrecipients. Related Noncompliance – Noncompliance. Views of Responsible Officials and Planned Corrective Actions – While DMPSJ doesn’t agree that it is out of compliance, DMPSJ will ensure documentation is maintained regarding its oversight of grant management. ONSE acknowledges and accepts the finding that the subrecipient failed to submit their monthly and performance reports. The District’s corrective action is described in the Management’s Corrective Action Plan included as Appendix B of the attached Management’s Section. BDO’s Response – We have reviewed management’s response and our finding remains as indicated.
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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
2024-001 – Subrecipient Monitoring Cluster: Research and Development Cluster (“R&D Cluster”) Grantor: Various - All R&D Cluster awards with subrecipients Award Name: Various - All R&D Cluster awards with subrecipients Award Year: FY2024 Assistance Listing Number: Various – All R&D Cluster awards with subrecipients Pass-through entities and ID Number: Various - All R&D Cluster awards with subrecipients Condition The University has a detailed pre-award risk assessment process prior to entering into a subrecipient relationship, which includes review of subrecipient Uniform Guidance reports. Subsequent review of Uniform Guidance reports for monitoring purposes is completed at the time of a subaward amendment. However, subawards are not always amended within a year, which creates a potential gap in review. In the FY2023 audit, 4 out of the 25 subaward selections did not have a Uniform Guidance report review or other monitoring review during the year, which resulted in a reportable finding. In FY2024, in response to the FY2023 finding in subrecipient monitoring (2023-001), the University implemented an annual Post-Award review of all subrecipient Uniform Guidance reports. This review documented the report information, findings noted, and follow-up performed with the subrecipient, as necessary. However, this consolidated review was deemed to be incomplete, as 1 of the 25 subrecipient selections was not included in the Post-Award review of all subrecipient Uniform Guidance reports. Management subsequently reviewed the completeness of the consolidated review, and determined a total of 12 subrecipients were not monitored in FY2024. Criteria 2 CFR 200.332(d) notes that pass-through entity monitoring of the subrecipient must include: • Reviewing financial and performance reports required by the pass-through entity. • Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. • Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Additionally, 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Cause In compiling the consolidated analysis of all subrecipients with active funding during the fiscal year, the Post-Award team utilized reporting of subrecipient expenditures from the general ledger. This report inadvertently omitted a period of time during the fiscal year, which caused omission of select subrecipients from the consolidated Post-Award analysis. Effect The lack of an annual review of subrecipient Uniform Guidance reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the Uniform Guidance. Questioned Costs There are no questioned costs associated with this finding. Through audit procedures, there was no evidence of non-compliance from subrecipients. Recommendation We recommend the University address the completeness of their consolidated subrecipient monitoring through review of the reports used to compile the analysis. 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