Finding Text
FINDING 2021-003 - Subrecipient Monitoring (Repeated from Prior Year Findings 20-004, 19-005, 18-004, and 17-003)
Federal Program: Individuals with Disabilities Education Act (IDEA) Improvement Grant - Part D Project No: 20-4631-RN and 21-4631-RN
Federal Assistance
Listing Number: 84.323A
Passed Through: Illinois State Board of Education
Federal Agency: U.S. Department of Education
Criteria/Specific Requirement:
A. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require the Regional Office to ensure any subrecipient monitoring using federal funds be consistent with the standards set forth in the Uniform Guidance at 2 CFR 200.332.
B. The Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 Internal Controls states the following: “The non-Federal entity must:
Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition:
The ROE does not have effective internal controls over subrecipient monitoring. Furthermore, ROE #47 was not properly monitoring subrecipients in accordance with the Uniform Guidance standards. During audit testing procedures it was determined that ROE #47:
Number of Subrecipients
a. Did not evaluate the risk of noncompliance with Federal statutes, regulations,
and the terms and conditions of the subaward. 2 of 2
b. Did not conduct subrecipient monitoring procedures. 2 of 2
c. Did not determine whether the subrecipient met the 2 CFR 200 Subpart F Audit
requirements criteria for a single audit. 2 of 2
Questioned Costs:
None
Context:
The Regional Office of Education #47 expended a total of $1,919,044 of federal awards in fiscal year 2021, of which $879,747 in IDEA –Improvement Grant –Part D were passed-through to subrecipients.
Effect:
The Regional Office of Education #47 is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200.332 as it relates to subrecipient monitoring requirements. Additionally, the effect of noncompliance can result in questioned costs.
Cause:
The Regional Office of Education #47 experienced staff turnover and did not formally document policies and procedures that provide controls and structures to ensure all of its subrecipient monitoring accountabilities are conducted and complied with.
Recommendation:
We recommend that the Regional Office of Education #47 establish and maintain effective internal control over federal awards to ensure subrecipients are properly monitored as required by 2 CFR 200.332. This includes:
a. Evaluating the risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward;
b. Conducting subrecipient monitoring procedures; and
c. Determining whether the subrecipient met the requirement criteria of 2 CFR 200 Subpart F Audit requirements
for a single audit.
Management’s Response:
Management agrees with this finding.