Finding Text
METROPOLITAN TRANSPORTATION AUTHORITY
(A Component Unit of the State of New York)
SCHEDULE OF FINDINGS AND QUESTIONED COSTS- FEDERAL AWARDS (CONTINUED)
YEAR ENDED DECEMBER 31, 2023
Reference Number: 2023-001
Federal Agency: U.S. Department of Homeland Security
Federal Program: Rail and Transit Security Grant Program
ALN Number: 97.075
Contract Number: FE2019-RA-00004; FE2020-RA-00005; FE2021-RA-00004; FE2022-RA-00006
Compliance Requirement: Subrecipient Monitoring
Type of Finding: Deficiency-Non-Compliance
1. CRITERIA
Subrecipient Monitoring - As stated in Uniform Grant Guidance - §200.331 Requirements for pass-through entities, all pass-through entities must:
Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes:
• Subrecipient name (which must match the name associated with its unique entity identifier);
• Subrecipient’s unique entity identifier;
• Federal Award Identification Number (FAIN);
• Assistance Listing Number (ALN) Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the ALN number at time of disbursement;
• Identification of whether the award is Research & Development; and
• Indirect cost rate for the Federal award (including if the de minimis rate is charged per §200.414 Indirect (F&A) costs);
2. CONDITION/PERSPECTIVE
Metropolitan Transportation Authority (“MTA”) has subrecipient monitoring procedures in place. MTA has corporate policies and procedures regarding subrecipient contracts.
We reviewed Rail and Transit Security Grant Program’s subrecipient monitoring compliance. This program had one subrecipient. Based on our review of the subrecipient contract for this program, we noted that the subrecipient contract did not have all the required elements as stated in §200.331.
3. CAUSE
MTA did not ensure that the contract between MTA and the subrecipient included the ALN and all other required elements as required by 2 CFR; §200.331.
4. EFFECT
The Subrecipient may not identify an MTA contract as a federal program, and therefore may not follow the required federal award requirements. Additionally the subrecipient may not include the program in the Subrecipient’s schedule of expenditures of federal awards and the program may not be audited as part of the Subrecipient’s single audit.
5. REPEAT FINDING
No
6. RECOMMENDATION
We recommend that MTA implement policies and procedures to communicate the federal grant information to all subrecipients in accordance with Uniform Grant Guidance CFR 200.331 Subrecipient Requirements.
7. QUESTIONED COST
None.
8. VIEWS OF RESPONSIBLE OFFICIAL
The MTA Office of Security is acknowledging the sub-recipient agreement did not include the ALN Number – 97.075, Identification of whether the award is R&D and Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414 on the check list. The MTA does provide a copy of the award letter to our sub-recipient(s) and we perform yearly sub-recipient monitoring of our sub-recipient(s).
Also, see “Corrective Action Plan”.