Finding Text
Criteria: All pass-through entities must perform certain identification and monitoring procedures
over subrecipients, including but not limited to the following:
-A pass-through entity must ensure that every subaward is clearly identified to the
subrecipient as a federal subaward and includes the following specific required
information: federal award identification information, all requirements imposed by the
pass-through entity, any additional requirements to meet the pass-through entity’s
responsibilities, information on the indirect cost rate, requirements to permit access to
subrecipients’ records and statements, and appropriate closeout terms and conditions (2
CFR section 200.332).
-A pass-through entity must ascertain that subrecipients expected to be audited as required
by 2 CFR Part 200, Subpart F, met this requirement (2 CFR section 200.331(f)). This
verification may be performed as part of the required monitoring under 2 CFR section
200.331(d)(2) to ensure that the subrecipient takes timely and appropriate action on
deficiencies detected though audits.
-When a non-federal entity enters into a covered transaction with an entity at a lower tier,
the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and
agency adopting regulations, is not suspended or debarred or otherwise excluded from
participating in the transaction. All non-procurement transactions entered into by a passthrough
entity, including subawards to subrecipients, are considered covered transactions.
Condition: The subaward agreements for the COVID-19 – Coronavirus State and Local Fiscal
Recovery Funds did not include the required federal identification information per 2 CFR section
200.332. Additionally, there were no processes in place to ensure subrecipients were not
suspended or debarred or to ensure the required review and follow up of subrecipient's audit findings was performed.
Cause: Jewish Family and Children’s Service of Minneapolis was not aware of these
responsibilities, and they were not outlined or clearly communicated in the original grant
agreement.
Effect: The conditions noted above resulted in noncompliance over subrecipient monitoring.
Context: A sample of two subrecipients was selected for audit from a population of four.
Questioned Costs: $0
Identification of Repeat Finding: The finding is not a repeat finding.
Recommendation: Jewish Family and Children’s Service of Minneapolis should examine and
update its subrecipient monitoring policies and ensure they conform to Uniform Guidance
requirements and guidelines.
Views of Responsible Officials and Planned Corrective Actions: Jewish Family and Children’s
Service of Minneapolis agrees with the finding and is in the process of re-evaluating its
subrecipient monitoring policies to include all requirements of the Uniform Guidance.