Finding 1062087 (2023-002)

Subrecipient Monitoring Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: Wisconsin Department of Health Services Pass-Through Number: 155811 Federal Award Identification Number and Year: SLFRP0756; 2020 Award Period: March 1, 2020 – December 31, 2024 Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: 2 CFR section 200.332 states that once a pass-through entity has made the decision between subrecipient versus contractor determination, 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. Condition: The County did not follow their established controls related to ensuring subrecipient monitoring policies were followed. Questioned Costs: $300,000 Context: While performing compliance procedures, it was noted that the County did not follow their policy to ensure compliance with subrecipient monitoring requirements. Cause: While the County's grant administration policy discusses the steps needed to monitor subrecipients, the County did not have a designated individual to follow up on the monitoring of the subrecipient to ensure compliance. Effect: The County is not in compliance with subrecipient monitoring requirements. Grant funding received by a subrecipient could be used in a manner that is not compliant with Uniform Guidance. Repeat Finding: No Recommendation: We recommend the County review internal policies and procedures regarding who is responsible for monitoring the subrecipient in order to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. View of Responsible Officials: There is no disagreement with the finding.