2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) 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 Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) 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 Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.
2022 ? 001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus Relief Fund Assistance Listing Number: 21.019 Federal Award Identification Number and Year: SLT0198 Pass-Through Agency: County of Los Angeles Pass-Through Number: Unknown Award Period: March 1, 2020 through December 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: 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 (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: ? Reviewing financial and programmatic (performance and special reports) required by the PTE. ? 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. ? Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition: During our testing, we noted LAHSA did not have adequate internal controls designed to properly monitor its? subrecipients. Questioned costs: Unable to determine. Context: During our testing of subrecipient monitoring, it was noted that LAHSA did not monitor 1 out of 8 subrecipients tested. The subrecipient received $169,035 for the fiscal year ended June 30, 2022. Cause: LAHSA's new subrecipient monitoring process was not implemented until January 2022. At that time, the subrecipients that were not monitored did not have an active contract with federal funding. As such, they were deemed to be low risk. LAHSA does not have a policy in place to ensure that the subrecipient monitoring plan and risk assessment is revisited throughout the year to ensure new contracts are assessed and monitored appropriately. Effect: LAHSA did not perform required monitoring over subrecipients of federal funding. The lack of internal controls over this compliance requirement provides an opportunity for noncompliance by subrecipients of the grant. Repeat Finding: Yes. Recommendation: We recommend LAHSA implements controls to ensure that the subrecipient monitoring plan is revisited at the time contracts are entered into in order to ensure proper coverage. Views of responsible officials: There is no disagreement with the audit finding.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
2022-006 (2019-015) SUBRECIPIENT MONITORING ? Repeated and Modified Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants ? 97.042 Fire Management Assistance Grants ? 97.046 Pre-Disaster Mitigation ? 97.047 Homeland Security Grant Program ? 97.067 Award Period: Various Type of Finding: Material Weakness in Internal Control over Compliance Material Noncompliance (Modified Opinion) Questioned Costs: None Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. ? All o The Department lacked evidence that a risk assessment was performed for subrecipients as relates to the risk of noncompliance for those subawards subject to the Uniform Guidance. o The Department lacked a process for all federal programs to review the audits of subrecipients that would allow the Department to identify any potential deficiencies that would require follow-up. o The Department lacked a process to ensure timely reporting by subgrantees of financial reporting and performance reporting. Also, the Department lacked a process to ensure timely review of reports submitted by subgrantees. Management?s Progress for Repeated Findings: Management failed to implement adequate controls to resolve the finding from the prior years. Criteria: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department?s sub-grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department?s approved sub-recipients for monitoring purposes and risk designation. Effect: The auditor noted instances of material noncompliance. Noncompliance results in possible federal funds provided to ineligible subrecipients. Also, the lack of internal controls over this compliance requirement provides an opportunity for noncompliance at the subrecipient level. Potential costs outside the scope of work as well as overall effective project management at the subrecipient level. Cause: The program staff continue to not operate under the Sub-Grant Recipient Monitoring effective June 30, 2017. The Department continues to lack established internal controls and procedures over financial grant management to ensure compliance with applicable compliance requirements.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Cluster: Research and Development Federal Agency: All awards with subrecipients on the SEFA Award Names: All awards with subrecipients on the SEFA Award Numbers: All awards with subrecipients on the SEFA Assistance Listing Title: All awards with subrecipients on the SEFA Assistance Listing Number: All awards with subrecipients on the SEFA Award Year: 2021 - 2022 Pass-through entity: All pass-through entities noted on the SEFA Criteria 2 CFR 200.332 notes that pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. Further, Uniform Guidance 2 CFR section 200.331(f) requires that the entity verify that every subrecipient is audited as required by Subpart F? Audit Requirements when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501 Audit requirements ($750,000). Condition In testing conformity with the compliance requirements for subrecipient monitoring, we selected 7 of the 61 Research and Development subrecipient agreements and the one Opioid STR subrecipient agreement from the detailed listings provided for testing. The total federal funds passed through to subrecipients in FY22 amounted to $3.5 million for the Research & Development Cluster, and $24,500 for the Opioid STR program. For all of our selections, the most recent audit report was not reviewed for purposes of ongoing monitoring as required by the Uniform Guidance. The Health System has a risk assessment form that is completed at contract inception for its subrecipients; however, the risk assessment is not reassessed annually for all subrecipients. The most recent risk assessment form was conducted in 2018 for 2 selections, in 2019 for 2 selections, in 2020 for 2 selections and in 2021 for 2 selections. We further noted that 7 of the 8 risk assessment forms selected for testing did not include explicit documentation detailing the subrecipient audit report review (such as what year was reviewed, what were the results of the review, etc.). Additionally, for one selection, the initial subrecipient risk assessment form was reviewed after the subrecipient award agreement was executed. Cause The Health System?s subrecipient policy does not explicitly state the ongoing monitoring activities that must be conducted or the frequency of required monitoring. For instance, the policy does not outlinemonitoring activities that are required for all subrecipients. Additionally, the risk assessment form does not prescribe the details of the subrecipient audit report review that should be documented. Effect The subrecipients of the Health System may have audit findings pertaining to the Federal award provided from the Health System that may have implications on the compliance of the Health System with Uniform Guidance. Additionally, there may be changes in the risk characteristics of subrecipients that are not identified if risk assessments are not periodically updated. Questioned Costs None noted. Recommendation We recommend that he Health System update its subrecipient monitoring policy to reflect all monitoring compliance requirements of the Uniform Guidance. In particular, the policy should require the receipt of the Uniform Guidance report from all subrecipients that expended $750,000 or more in federal awards during the subrecipient?s fiscal year (or the receipt of the subrecipient?s latest financial statements if not) at contract inception. Any audit findings pertaining to the Federal award should be followed up on by the Health System and a management decision should be issued. This Policy should be distributed and adhered to by all that have a role in the subrecipient monitoring process of the Health System. Management?s Views and Corrective Action Plan Management?s response is included in ?Management?s Views and Corrective Action Plan? included at the end of this report after the summary schedule of status of prior audit findings.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.
Program: Housing Voucher Cluster Assistance Listing No.: 14.871, 14.879 Federal Agency: U.S. Department of Housing and Urban Development Passed-through: n/a ? direct award Award Number and Year: CA131, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1) Reviewing of financial and performance reports as required by the pass-through entity. 2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means. 3) Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: No known questioned costs identified. Context/Sampling: We selected 100% of the County?s subrecipients of the program. Repeat Finding from Prior Year(s): Yes, prior year finding 2021-004. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.