Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
Finding No. 2023-002: Subrecipient Monitoring Federal Program Research and Development Cluster (multiple ALNs) Federal Award Year July 1, 2022 to June 30, 2023 Federal Award Agencies U.S. Department of Health and Human Services; National Science Foundation Criteria or Requirement Per CFR section 200.332(b), a pass-through entity (PTE) must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. This evaluation of risk may include consideration of such factors as the following: 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 single audits in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; 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. Per 2 CFR sections 200.332(d) through (f), a pass-through entity (PTE) must 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. In addition to the 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. Per 2 CFR 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition and Context In thirty-eight of forty samples totaling $2,821,079, there was no documentation showing that the University evaluated the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitored the activities of the subrecipient to ensure that the subaward complies with the terms and conditions of the subaward, and achieves performance goals. Cause and Potential Effect The University has a protocol in place outlining required risk evaluation and monitoring of subrecipients. Certain monitoring procedures were performed; however, the risk assessment process and the monitoring procedures related to review of subrecipient Uniform Guidance reports were not performed on a consistent basis due to certain transitions which occurred during the year. Questioned Costs None. Statistically Valid Sample The sample was not intended to be not, and was, a statistically valid sample. Identification of Whether the Audit Finding is a Repeat of a Finding in the Immediately Prior Audit This is not a repeat finding. Recommendation The University should continue to follow their established protocol and document the review of their ongoing risk evaluation and monitoring process for all subrecipients. View of Responsible Officials We concur with the auditor’s assessment that subrecipient monitoring did not happen in the auditor’s desired time frame, but as of publication of this report all monitoring activities have been completed for fiscal year 2023 and will be completed for fiscal year 2024 prior to our next audit cycle.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable 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. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.
2023-001 Subrecipient Monitoring Cluster: Research and Development Cluster Grantor: Department of Health and Human Services and National Aeronautics and Space Administration Award Names: Biomedical Research and Research Training and Science Award Year: July 1, 2022 – June 30, 2023 Award Number: 5R01GM140457-03 and 80NSSC21K0753 Assistance Listing Numbers: 93.859 and 43.001 Pass-through entity: Not applicable 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. 2 CFR 200.332(f) notes that a pass-through entity must verify that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501. Additionally, 2 CFR 200.332(b) indicates that entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section of the guidance. In this respect, the College procedures include (amongst other items) obtaining a Commitment Form from the subrecipient, performing an initial risk assessment on all subrecipients, and updating that risk assessment based on the Controller Office’s judgement. The College also annually reviews the subrecipient's Uniform Guidance (“UG”) report and performs any necessary follow-up to issue a management decision, where applicable. Condition Through our testing of 4 subrecipients, we noted the following: • For all samples, we were unable to obtain sufficient evidence of the College’s annual subrecipient risk assessment. • For all samples, we were unable to obtain sufficient evidence of the College’s annual review of the audited financial statements and UG report, documentation of their review of the subrecipient’s audit report, and actions taken as a result of the findings in the report. Cause The College indicated subrecipient reviews, including the annual risk assessment and review of the UG report, were performed informally by the Principal Investigators and financial staff and not consistently documented. The College cites insufficient staffing needed for the formal documentation of the subrecipient risk assessment and monitoring procedures as the cause. Effect The lack of an annual review of subrecipient UG reports may result in potential compliance issues not being identified and management not addressing findings and issuing a management decision, as required under the UG. In addition, the lack of review of the risk assessment form may result in missing information not being identified. Questioned Costs None identified. Recommendation We recommend the College reassess the design of its controls around subrecipient risk assessment and monitoring during the ongoing monitoring process. The College should formalize the documentation and review of its controls related to the annual monitoring of subrecipients, inclusive of annual reviews of Uniform Guidance reports along with other required ongoing monitoring based on the risk rating of the subrecipient. Management’s Views and Corrective Action Plan Management’s Views and Corrective Action Plan are included at the end of this report after the summary schedule of prior audit findings.
(2023-059) Title: Internal control over CSLFRF subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Economic and Community Development State Bureau: Commissioner’s Office Federal Agency: U.S. Department of the Treasury Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds (COVID-19) Assistance Listing Number: 21.027 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 2 CFR 200.521 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must follow-up and ensure 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. The Department must verify that every subrecipient is audited as required by 2 CFR 200, subpart F regarding audit requirements. Furthermore, the Department must issue a management decision for audit findings that relate to Federal awards provided to the subrecipient within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Condition: As part of the American Rescue Plan Act, the State was advanced $997 million in Federal Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) to support its response to and recovery from the COVID-19 public health emergency. The Department of Economic and Community Development (DECD) partnered with subrecipients to support the administration of CSLFRF. The Office of the State Auditor (OSA) selected a sample of three DECD subrecipients subject to Single Audit requirements outlined in 2 CFR 200, subpart F and identified that DECD did not review the subrecipients’ Single Audits. Additionally, one of the subrecipient Single Audit Reports included a CSLFRF finding for not verifying whether beneficiaries were suspended or debarred; DECD did not issue a management decision as required by Federal regulations. OSA selected a non-statistical random sample. Context: For fiscal year 2023, CSLFRF expenditures totaled $207.8 million, of which approximately $55 million was provided to 12 DECD subrecipients. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients may not be complying with Federal statutes, regulations, or the terms and conditions of the subaward. Recommendation: We recommend that the Department enhance policies and procedures to ensure that audit reports for all subrecipients receiving over $750,000 in Federal awards requiring audits are properly reviewed, and management decisions are issued timely. Corrective Action Plan: See F-27 Management’s Response: The Department agrees with this finding. The selected sample of subrecipient single audits were not reviewed in keeping with federal guidance in 2 CFR 200 and management decision letters were not issued. Moving forward DECD will engage their consulting firm to conduct regular reviews of subrecipient single audits and work with DECD staff to issue timely and actionable management decisions. Contact: Denise Garland, Deputy Commissioner, DECD, 207-624-7496 (State Number: 23-1699-02)
(2023-063) Title: Internal control over Special Education subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner’s Office Special Services & Inclusive Education Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 2 CFR 200.521 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must follow-up and ensure 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. The Department must issue a management decision for audit findings that relate to Federal awards provided to the subrecipient within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Condition: The Department of Education’s (DOE) School Finance and Operations team within the Commissioner’s Office, in conjunction with DOE’s Office of Special Services & Inclusive Education, is responsible for tracking and reviewing subrecipient audits and issuing management decisions on Special Education Cluster (SEC) subrecipient audit findings. SEC program subrecipients consist of Local Education Agencies and organizations that are provided Federal funding for special education programs. The Office of the State Auditor (OSA) reviewed 23 SEC subrecipients to ensure proper tracking and review of Single Audit Reports, audit findings, and DOE management decisions in response to findings related to SEC funding. For 2 of the 23 subrecipients, OSA requested documentation of management decisions pertaining to findings included in the Single Audit Reports. DOE could not provide management decision letters documenting consideration, review, and approval of the subrecipients’ corrective action plans. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds, of which $66.8 million was provided to 258 subrecipients. Based on OSA’s review, approximately 120 subrecipients were required to undergo a Single Audit in accordance with Federal regulations. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients not complying with Federal statutes, regulations, or the terms and conditions of SEC subawards may not be implementing appropriate corrective action in response to audit findings. Recommendation: We recommend that the Department enhance policies and procedures to ensure that adequate documentation is maintained during the review of audit findings, and that management decisions related to audit findings and corrective action are issued timely to subrecipients. Corrective Action Plan: See F-28 Management’s Response: The Department agrees with this finding. The Department will review the current procedure regarding the notification of management decisions related to audit findings and corrective action, to strengthen the areas where prior notifications were missed. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-01)
(2023-063) Title: Internal control over Special Education subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner’s Office Special Services & Inclusive Education Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 2 CFR 200.521 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must follow-up and ensure 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. The Department must issue a management decision for audit findings that relate to Federal awards provided to the subrecipient within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Condition: The Department of Education’s (DOE) School Finance and Operations team within the Commissioner’s Office, in conjunction with DOE’s Office of Special Services & Inclusive Education, is responsible for tracking and reviewing subrecipient audits and issuing management decisions on Special Education Cluster (SEC) subrecipient audit findings. SEC program subrecipients consist of Local Education Agencies and organizations that are provided Federal funding for special education programs. The Office of the State Auditor (OSA) reviewed 23 SEC subrecipients to ensure proper tracking and review of Single Audit Reports, audit findings, and DOE management decisions in response to findings related to SEC funding. For 2 of the 23 subrecipients, OSA requested documentation of management decisions pertaining to findings included in the Single Audit Reports. DOE could not provide management decision letters documenting consideration, review, and approval of the subrecipients’ corrective action plans. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds, of which $66.8 million was provided to 258 subrecipients. Based on OSA’s review, approximately 120 subrecipients were required to undergo a Single Audit in accordance with Federal regulations. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients not complying with Federal statutes, regulations, or the terms and conditions of SEC subawards may not be implementing appropriate corrective action in response to audit findings. Recommendation: We recommend that the Department enhance policies and procedures to ensure that adequate documentation is maintained during the review of audit findings, and that management decisions related to audit findings and corrective action are issued timely to subrecipients. Corrective Action Plan: See F-28 Management’s Response: The Department agrees with this finding. The Department will review the current procedure regarding the notification of management decisions related to audit findings and corrective action, to strengthen the areas where prior notifications were missed. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-01)
(2023-063) Title: Internal control over Special Education subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner’s Office Special Services & Inclusive Education Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 2 CFR 200.521 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must follow-up and ensure 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. The Department must issue a management decision for audit findings that relate to Federal awards provided to the subrecipient within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Condition: The Department of Education’s (DOE) School Finance and Operations team within the Commissioner’s Office, in conjunction with DOE’s Office of Special Services & Inclusive Education, is responsible for tracking and reviewing subrecipient audits and issuing management decisions on Special Education Cluster (SEC) subrecipient audit findings. SEC program subrecipients consist of Local Education Agencies and organizations that are provided Federal funding for special education programs. The Office of the State Auditor (OSA) reviewed 23 SEC subrecipients to ensure proper tracking and review of Single Audit Reports, audit findings, and DOE management decisions in response to findings related to SEC funding. For 2 of the 23 subrecipients, OSA requested documentation of management decisions pertaining to findings included in the Single Audit Reports. DOE could not provide management decision letters documenting consideration, review, and approval of the subrecipients’ corrective action plans. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds, of which $66.8 million was provided to 258 subrecipients. Based on OSA’s review, approximately 120 subrecipients were required to undergo a Single Audit in accordance with Federal regulations. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients not complying with Federal statutes, regulations, or the terms and conditions of SEC subawards may not be implementing appropriate corrective action in response to audit findings. Recommendation: We recommend that the Department enhance policies and procedures to ensure that adequate documentation is maintained during the review of audit findings, and that management decisions related to audit findings and corrective action are issued timely to subrecipients. Corrective Action Plan: See F-28 Management’s Response: The Department agrees with this finding. The Department will review the current procedure regarding the notification of management decisions related to audit findings and corrective action, to strengthen the areas where prior notifications were missed. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-01)
(2023-063) Title: Internal control over Special Education subrecipient audit procedures needs improvement Prior Year Findings: None State Department: Education State Bureau: Commissioner’s Office Special Services & Inclusive Education Federal Agency: U.S. Department of Education Assistance Listing Title: Special Education Cluster (IDEA) (COVID-19) Assistance Listing Number: 84.027, 84.173 Federal Award Identification Number: See E-93 to E-94 Compliance Area: Subrecipient monitoring Type of Finding: Significant deficiency Questioned Costs: None Criteria: 2 CFR 200.303; 2 CFR 200.332; 2 CFR 200.521 The Department must establish and maintain effective internal control over Federal awards that provides reasonable assurance that the Department is managing awards in compliance with Federal statutes, regulations, and the terms and conditions of awards. The Department must follow-up and ensure 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. The Department must issue a management decision for audit findings that relate to Federal awards provided to the subrecipient within six months of acceptance of the audit report by the Federal Audit Clearinghouse. Condition: The Department of Education’s (DOE) School Finance and Operations team within the Commissioner’s Office, in conjunction with DOE’s Office of Special Services & Inclusive Education, is responsible for tracking and reviewing subrecipient audits and issuing management decisions on Special Education Cluster (SEC) subrecipient audit findings. SEC program subrecipients consist of Local Education Agencies and organizations that are provided Federal funding for special education programs. The Office of the State Auditor (OSA) reviewed 23 SEC subrecipients to ensure proper tracking and review of Single Audit Reports, audit findings, and DOE management decisions in response to findings related to SEC funding. For 2 of the 23 subrecipients, OSA requested documentation of management decisions pertaining to findings included in the Single Audit Reports. DOE could not provide management decision letters documenting consideration, review, and approval of the subrecipients’ corrective action plans. OSA selected a non-statistical random sample. Context: In fiscal year 2023, the Department expended $71.6 million in SEC program funds, of which $66.8 million was provided to 258 subrecipients. Based on OSA’s review, approximately 120 subrecipients were required to undergo a Single Audit in accordance with Federal regulations. Cause: • Lack of adequate policies and procedures • Lack of supervisory oversight Effect: • Noncompliance with Federal regulations • Subrecipients not complying with Federal statutes, regulations, or the terms and conditions of SEC subawards may not be implementing appropriate corrective action in response to audit findings. Recommendation: We recommend that the Department enhance policies and procedures to ensure that adequate documentation is maintained during the review of audit findings, and that management decisions related to audit findings and corrective action are issued timely to subrecipients. Corrective Action Plan: See F-28 Management’s Response: The Department agrees with this finding. The Department will review the current procedure regarding the notification of management decisions related to audit findings and corrective action, to strengthen the areas where prior notifications were missed. Contact: Nicole Denis, Director of Finance, DOE, 207-530-2161 (State Number: 23-1201-01)
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
U.S. Department of Transportation, Passed through Nebraska Department of Transportation and Iowa Department of Transportation Highway Planning and Construction Assistance Listing Number 20.205 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Criteria: A pass‐through entity (PTE) must: Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). This evaluation of risk may include consideration of such factors as the following: o The subrecipient’s prior experience with the same or similar subawards; o The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR Part 200, Subpart F, and the extent to which the same or similar subaward has been audited as a major program; o Whether the subrecipient has new personnel or new or substantially changed systems; and o The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: o Reviewing financial and programmatic (performance and special reports) required by the PTE. o Following‐up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on‐site reviews, and other means o Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521.Verify that every subrecipient is audited as required by Uniform Guidance when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. Consider whether the results of the subrecipient's audits, on‐site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass‐through entity's own records. Condition: MAPA is the pass‐through entity for several subrecipients. MAPA does not appear to have a formal policy to evaluate each subrecipient’s risk of noncompliance for appropriate subrecipient monitoring. Further, MAPA does not have a formal policy to monitor the activities of the subrecipients to the extent deemed necessary by the federal government, including the verification that subrecipients are audited when they reach Uniform Guidance spending levels and evaluation of those audits. However, the current procedures require a review of the subrecipients’ invoices, including all detailed costs by an appropriate individual at MAPA prior to payment. This process helps reduce risk of inappropriate funding to subrecipients. Cause: MAPA does not appear have formal policies in place for all of the subrecipient monitoring requirements. Effect: MAPA may not have appropriate monitoring levels established for all of its subrecipients and have awareness of where subrecipient deficiencies may exist. Questioned Costs: None reported. Context: We reviewed two of the five subrecipients within this program that did not appear to have any formal risk evaluation and monitoring plan in place. Repeat Finding From Prior Year: No Recommendation: The policy should be updated to include all federal requirements for subrecipient monitoring and updated on a regular basis as those regulations change. Views of Responsible Officials: We agree with the finding.
Cluster name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO—Student Support Services 84.047 TRIO—Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022; P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025; P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $5,612 Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that: • For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures. • For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so. Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that: • For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program. Effect—Without performing independent reviews and approvals of eligibility determinations that the colleges’ policies and procedures require, GateWay and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2 Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility. Criteria—GateWay Community College’s written policies and procedures require employees to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College—TRIO Upward Bound Eligibility Determination and Intake Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should: 1. Require all the District colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants. 2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures. 3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-105 and was initially reported in fiscal year 2022. 1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)
Cluster name: TRIO Cluster Assistance Listings numbers and names: 84.042 TRIO—Student Support Services 84.047 TRIO—Upward Bound Award numbers and years: P047A171009, September 1, 2017 through August 31, 2022; P047A170820, September 1, 2017 through August 31, 2023; P042A200873, P042A201342, and P042A200859, September 1, 2020 through August 31, 2025; P047A221154 and P047A221160, September 1, 2022 through August 31, 2027 Federal agency: U.S. Department of Education Compliance requirement: Eligibility Questioned costs: $5,612 Condition—We identified 2 issues related to eligibility. First, for 2 of the 3 District colleges that administer the TRIO Cluster, the colleges did not review and approve eligibility determinations for 20 of 60 students we tested.1 Specifically, we found that: • For 10 of 28 students tested, GateWay Community College did not independently review and approve its eligibility determinations before awarding students services, contrary to its policies and procedures. • For 10 of 10 students tested, South Mountain Community College did not independently review and approve its eligibility determinations before awarding students services and lacked procedures to do so. Second, contrary to federal regulation, 1 of the 3 District’s colleges that administers the Student Support Services program awarded 6 of 20 students grant aid when the students did not meet eligibility requirements. Specifically, we found that: • For 6 of 20 students it awarded grant aid, GateWay Community College informed us that it incorrectly awarded grant aid totaling $5,612 to these ineligible students because the students did not receive a federal Pell Grant, which is an eligibility criterion to receive grant aid for the Student Support Services program. Effect—Without performing independent reviews and approvals of eligibility determinations that the colleges’ policies and procedures require, GateWay and South Mountain Community Colleges have an increased risk of ineligible students participating in the program. In addition, GateWay Community College could potentially be required to repay to the federal agency the $5,612 of awards it made to ineligible students.2 Cause—GateWay and South Mountain Community Colleges both experienced turnover in key personnel administering the TRIO Cluster. The new personnel at GateWay Community College were not aware of its policies and procedures requiring review and approval of eligibility determinations and grant aid requirements. South Mountain Community College’s policies and procedures did not address review and approval of student records in determining eligibility. Criteria—GateWay Community College’s written policies and procedures require employees to perform an independent review and approval of their student eligibility determinations before awarding students program services (GateWay Community College—TRIO Upward Bound Eligibility Determination and Intake Process). Also, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms (2 CFR §200.303). Recommendations—The District should: 1. Require all the District colleges that administer the TRIO Cluster to follow or update policies and procedures to require an independent and knowledgeable employee to review and approve student eligibility determinations before awarding program services to them. This includes procedures to verify whether students meet all eligibility requirements, including whether they were awarded federal Pell Grants. 2. Train all employees responsible for administering the TRIO programs at the colleges on the District-wide policies and procedures. 3. Work with Gateway Community College and the U.S. Department of Education to resolve the $5,612 in questioned costs. The District’s corrective action plan at the end of this report includes the views and planned corrective action of its responsible officials. We are not required to audit and have not audited these responses and planned corrective actions and therefore provide no assurances as to their accuracy. This finding is similar to prior-year finding 2022-105 and was initially reported in fiscal year 2022. 1 For 22 of the 22 students tested for Mesa Community College, we found that the College performed the eligibility determinations in compliance with federal regulations. 2 Federal Uniform Guidance requires federal awarding agencies to follow up on audit findings and issue a management decision to ensure the recipient, the Office, takes appropriate and timely corrective action (2 CFR §200.513[c]). Further, it requires that federal awarding agencies’ management decisions clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action, as directed by the federal awarding agencies (2 CFR §200.521)
Finding Reference Number: 2023-005 NH Department of Justice NH Department of Health and Human Services NH Department of Environmental Services NH Department of Business and Economic Affairs COVID-19 Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing #21.027) Federal Award Numbers: SLFRP0145 Federal Award Year: 2021 U.S. Department of Treasury Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-008 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorization purposes, complies with the terms and conditions of the subaward 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, per 2 CFR section 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Coronavirus State and Local Fiscal Recovery Funds program, the State of New Hampshire (the State) entered into grant agreements with local entities to support allowable activities under the federal program. During the year ended June 30, 2022, the State passed through $73,337,682 to subrecipients. As part of our testwork over the subrecipient monitoring process, we identified the following breakdown of internal controls: A. As part of our testwork over subrecipient monitoring, we selected a sample of 49 items from the listing of subrecipients provided by the State that reconciled to the amount reported on the Schedule of Expenditures of Federal Awards. Of the 49 items selected for testwork, 6 items were contracts and were not subrecipient agreements. As such, we were unable to determine the completeness and accuracy of the subrecipient population. As a result of our audit, the State identified that this error resulted in the amount reported on the Schedule of Expenditures of Federal Awards as pass-through expenditures to be overstated by $7,261,684. The State has corrected the Schedule of Expenditures of Federal Awards so that the amount reported is accurate. B. The State communicates award information to subrecipients through the approved grant agreement. For 19 of the 43 remaining subrecipients selected for testwork, the State did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) was not communicated for 19 of the 43 remaining subrecipients selected for testwork. b. Identification of whether the award is R&D was not communicated for 17 of the remaining 43 subrecipients selected for testwork. C. As part of our testwork over during the award monitoring, it was identified that subrecipient monitoring activities include the review and approval of invoices submitted for reimbursement from the subrecipient. During our testwork over the invoice review we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, we were unable to obtain the invoices paid by the State to verify that they were reviewed and approved. While the invoices were not provided to us, we noted that other monitoring procedures were performed for 4 of the 6 subrecipients. b. For 10 of the remaining 43 subrecipients selected for testwork, while we were able to obtain the invoices paid by the State, we were unable to properly identify who the appropriate reviewer was for the invoice to ensure that the individual who approved the invoice had the appropriate knowledge and competency to perform the review process. As a result, we were unable to verify if the invoice was appropriately reviewed. While we were unable to verify this, we noted that other monitoring procedures were performed for 9 of the 10 subrecipients. D. As part of our testwork over during the award monitoring, for 9 of the 43 remaining subrecipients selected for testwork, no documentation was provided to support that during the award monitoring procedures had been performed during the audit period. As such, we could not verify that appropriate monitoring procedures were performed as outlined by the subrecipient’s risk assessment. E. As part of our testwork over the review of Uniform Guidance Reports, we identified the following: a. For 6 of the remaining 43 subrecipients selected for testwork, the State provided the subrecipients Uniform Guidance report, however there was no evidence that the reports were reviewed to determine if a management decision letter needed to be issued. As part of our audit, we reviewed the 6 uniform guidance reports and did not identify any findings that would have required to be followed up on by the State. b. For 7 of the remaining 43 subrecipients selected for testwork, the subrecipient’s uniform guidance report was not provided. We reviewed the FAC to determine if a report was submitted during the audit period and identified that all 7 subrecipients had submitted a uniform guidance report. Of the 7 subrecipients, 1 report contained findings reported within Section III of the report. There was no evidence provided that the State had issued a management decision related to this subrecipient. Cause The cause of the condition found is primarily due to insufficient internal controls and procedures to ensure that award identification information is communicated, that appropriate during the award monitoring is performed based on the risk assessments and that all subrecipients are reviewed to determine if a uniform guidance audit was issued regardless of amount awarded to the subrecipient. Given the nature of this program, several Departments within the State entered into subrecipient grants resulting in a decentralized process. Not all Departments within the State are experienced with subrecipient relationships and may not have had developed policies to comply with subrecipient monitoring requirements. Finally, the State does not have sufficient internal controls in place to properly classify contracts and subrecipient relationships. Effect The effect of the condition found is that the State may not have properly monitored subrecipients in accordance with State policies and federal requirements. In addition, improper identification of contracts and subrecipients could lead to noncompliance with the State’s procurement policy or the proper monitoring of subrecipients. Questioned Costs None. Recommendation We recommend that the State review its existing internal controls, policies, and procedures to ensure that the State complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(d through (f), and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. Ensure that appropriate during the award monitoring is performed as outlined within the subrecipient’s risk assessment; and 3. All subrecipients are reviewed regardless of the amount awarded to determine if a uniform guidance report was issued and if a management decision letter should be issued. In addition, the State should continue to review its vendor determination policy to ensure that the policy is consistently applied across all Department’s within the State. View of Responsible Officials: Management concurs with the finding above.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-011 NH Department of Health and Human Services Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) and COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Assistance Listing #93.323) Federal Award Numbers: NUK50CK000522 Federal Award Year: 2019 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-018 Statistically Valid Sample: No Criteria A pass-through entity (PTE) must: 1. Evaluate Risk – Evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). 2. Monitor – Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: a. Reviewing financial and programmatic (performance and special reports) required by the PTE. b. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. c. Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Additionally, 45 CFR section 75 303(a) states the non Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award Condition During the year ended June 30, 2023, the New Hampshire Department of Health and Human Services (the Department) passed through $5,070,789 of federal funding to subrecipient. As part of our testing related subrecipient monitoring, we noted the following: A. As part of our during the award monitoring testwork, we were unable to obtain documentation to support that that the Department had performed the suggested monitoring procedures for 3 of the 4 subrecipients selected for testwork based upon the subrecipients most recent risk assessment performed. For the remaining 1 subrecipient, the risk assessment form did not indicate the required frequency of the suggested type of monitoring. As a result, we were not able to verify that the Department had performed the appropriate monitoring procedures as outlined by the risk assessment performed for each subrecipient. B. The Department’s during the award monitoring for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. Per review of the risk assessment for each of the 4 subrecipients, the risk assessment did not provide for specific monitoring procedures that would address compliance with the subrecipients grant agreement beyond the period review of expenditure data. Taking into consideration that for each of the 4 subrecipients selected the testwork, if an Uniform Guidance report was issued for the subrecipient, this program was not audited as a major program, it does not appear that either the procedures suggested within the risk assessment or the procedures performed by the Department would be able to identify noncompliance incurred at the subrecipient level. C. During our review over the Department’s review over the subrecipients Uniform Guidance reports, we identified the following: • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the subrecipients uniform guidance audit was not issued within 9 months of the subrecipients year end. We were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. • For 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report. We noted however there were no findings identified within the uniform guidance report that would have required corrective action. Cause The cause of the condition found was primarily due to a lack of formal policies and internal controls to ensure that all required subrecipient monitoring compliance procedures are being performed by the Department. Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). Questioned Costs None. Recommendation We recommend the Department develop policies and procedures and implement internal controls to ensure that the Department complies with 2 CFR section 200.332(b), 2 CFR sections 200.332(d) through (f), and 2 CFR section 200.501(h). This would ensure that the risk assessment is routinely updated for multiyear grants and that the prescribed monitoring procedures take into consideration any additional monitoring procedures that might need to be performed, such as a desk review or on-site visit, if the program is not audited as part of the subrecipient’s uniform guidance audit. In addition, policies and procedures should be established to ensure that if the risk assessment has suggested a particular monitoring procedure be performed, that the Department is adequately documenting its monitoring procedures to ensure that it has performed the required procedures. View of Responsible Officials: Management partially concurs with the finding above. Rejoinder As it relates to Bullet B above, for each of the 4 subrecipients selected for testwork consisted of the review and approval of subrecipient invoices. Per review of the invoices, the invoice contained a summary of costs incurred by the subrecipient by category of expense that it was seeking reimbursement for. The Department did not perform any other monitoring procedures to ensure the accuracy of the request made by the subrecipient through either a desk review or an on-site monitoring visit. We further noted that no other monitoring was performed by the Department to ensure that the subrecipient was complying with the terms and conditions of its subrecipient grant agreement. As it relates to Bullet C above, we were unable to obtain any correspondence between the Department or the subrecipient to inquire about the uniform guidance report or when it would be issued for 1 of 3 items selected for testwork. Upon receipt of the report, the Department did issue a management decision letter upon receipt of the report. In addition, for 1 of 3 subrecipients selected for testwork which had a Uniform Guidance audit, the Department did not issue a management decision letter within 6 months of receipt of the report.
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. 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 through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy
Finding Reference Number: 2023-015 NH Department of Energy Low Income Home Energy Assistance and COVID-19 Low Income Home Energy Assistance (Assistance Listing #93.568) Federal Award Numbers: 2001NHLEA, 2001NHLIE4, 2001NH5C3, 2101NHLIEA, 2101NHE5C6, 2201NHLIEA, 2101NHLIE4, 2201NHLIEE, 2201NHLIEI, 2301NHLIEA, 2301NHLIEE, 2301NHLIEI Federal Award Year: 2020, 2021, 2022, 2023 U.S. Department of Health and Human Services Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: 2022-025 Statistically Valid Sample: No Criteria A pass-through entity must: 1. Clearly identify to the subrecipient required award information and applicable requirements described in 2 CFR section 200.332(a); 2. Evaluate each subrecipient’s risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 300.332(b)); 3. 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 through the terms and conditions of the award, subaward monitoring must include following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and 4. Issuing a management decision for audit findings pertaining to federal award provided to the subrecipient from the subrecipient as required by 2 CFR section 200.521. Additionally, Title 45 U.S. Code of Federal Regulation Part 75 (45 CFR section 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HS Awards, section 75.303(a), Internal Controls, states the non-Federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-Federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition As part of the Low-Income Home Energy Assistance program (LIHEAP), the New Hampshire Department of Energy (the Department) enters into grant agreements with local entities to provide services related to the eligibility determination process for the LIHEAP program (including the calculation of participant benefits) and payment of benefits to fuel providers. During the year ended June 30, 2023, $52,485,098 was passed through to subrecipients. As part of our testwork over the subrecipient monitoring process, we noted the following as of the year ending June 30, 2023: A. The Department communicates award information to subrecipients through the approved grant agreement. Per review of the grant agreement, for each of the 3 subrecipients selected for testwork, the Department did not communicate all the required award information as outlined in 2 CFR section 200.332. Specifically, the following elements were not communicated: a. Federal Award Identification Number (FAIN) b. Federal award date c. Indirect cost rate for federal awards (including if the deminimus rate is charged per 2 CFR section 200.414) d. Identification of whether the award is R&D B. For the 1 programmatic monitoring review completed by the Department during the period under audit, the Department did not issue its programmatic monitoring report to the subrecipient timely after the monitoring review was completed. As a result, there was a delay in the subrecipient implementing its corrective action plan to address the findings identified during the programmatic monitoring review. Specifically, we noted the following: a. For the 1 programmatic monitoring review, the monitoring review took place on May 4, 2023, but the report to the subrecipient was not issued until September 23, 2023. Per review of the report that was issued, there were findings identified by the Department that warranted corrective action. Due to the delay in issuing the report, a corrective action plan was not obtained from the subrecipient until almost 5 months after the date of that the monitoring review took place. C. For 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy. D. During our testwork over the Department’s review of subrecipient uniform guidance reports, we noted the following: a. The Department does not track the receipt of uniform guidance reports. As a result, we were unable to determine when the uniform guidance reports were received by the Department to ensure they are reviewed timely. Specifically, we noted: i. For all 3 subrecipients selected, the subrecipient’s uniform guidance appeared to have been reviewed, but as the Department does not track the receipt of uniform guidance reports, it was unclear if it was reviewed timely. We did note based on the date that the uniform guidance report was issued, the management decision letter was not issued within 6 months of the date of the report being issued as required by 2 CRF 200.521 (d). ii. For 1 subrecipient in which the UG report had a finding, we were unable to obtain evidence to support that the Department had obtained and reviewed the subrecipient’s uniform guidance report, including management’s response to findings letter as well as the related Corrective Action Plan, as this subrecipient’s uniform guidance report noted a material weakness. E. The Annual Report on Households Assisted by LIHEAP contains data that is specific to benefits paid to eligible participants. The data that is used to compile the annual report is obtained from case data that is reported to the New Hampshire Department of Energy (the Department) from its subrecipients as the Department has entered into grant agreements with third parties who are responsible for the eligibility determination and benefit payment process. As part of our subrecipient monitoring testwork, we were unable to verify that the Department had performed any monitoring procedures over the data provided by each subrecipient to ensure that the data reported within the annual report was complete and accurate. Cause The cause of the condition found was primarily due to insufficient documented subrecipient policies and procedures to ensure that adequate monitoring is performed over subrecipients to align with the risk assessments performed. The monitoring procedures that are in place do not include the completeness and accuracy of the data submitted by the subrecipient utilized to compile federal reports. Further, the Department does not have sufficient internal controls and procedures to ensure results of monitoring visits are performed and results communicated timely to subrecipient or to ensure that subrecipient uniform guidance reports are obtained and reviewed timely. In addition, there are insufficient internal controls in place to review the grant agreements to ensure that all required data elements are communicated to the subrecipient in accordance with 2 CFR section 300.332(b). Effect The effect of the condition found is that the Department did not comply with 2 CFR section 200.332(a), section 200.332(b) and 2 CFR section 200.521. Questioned Costs None. Recommendation We recommend that the Department formalize, policies and procedures and implement the necessary internal controls to ensure that the Department complies with the provisions of 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.251. This would include ensuring that: 1. All required award information is communicated to subrecipients; 2. As a result of the risk assessment performed, monitoring activities are performed over subrecipients to ensure compliance with the terms and conditions of its subrecipient grant agreement. The results of all monitoring reviews should be timely communicated in accordance with the Department’s policies to the subrecipient and actions requiring corrective action plan should be followed up on to ensure that the matter is resolved; and 3. Ensure that all uniform guidance reports are collected and reviewed timely so that a management decision letter can be issued within the time period required by federal regulations. Retain evidence of Department review of uniform guidance reports and management letters issued as a result of their review. View of Responsible Officials: Management partially concurs with the finding above Rejoinder As it relates to Bullet C above, for 3 of 3 subrecipients selected for testwork, the Department did not complete its annual fiscal monitoring review during the audit period as required by their monitoring policy