Finding Text
Awards to Subrecipients: Criteria – The Uniform Guidance, Part 200.332 states, “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, in part, subrecipient's unique entity identifier, federal award identification number (FAIN), federal award date of award to the recipient by the Federal agency, subaward period of performance start and end date, subaward budget period start and end date, name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity, assistance listings number and title, identification of whether the award is research and development (R&D) and indirect cost rate for the federal award (including if the de minimis rate is charged) per Part 200.414. In addition, required information includes all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and appropriate terms and conditions concerning closeout of the subaward. Condition – The District did not clearly identify to the subrecipient that the subaward was a subaward. In addition, the District did not include the subrecipient's unique entity identifier, federal award identification number (FAIN), federal award date of award to the recipient by the Federal agency, subaward period of performance start and end date, subaward budget period start and end date, name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity, assistance listings number and title, identification of whether the award is research and development (R&D) and indirect cost rate for the federal award (including if the de minimis rate is charged) per Part 200.414, all requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award, and appropriate terms and conditions concerning closeout of the subaward in the subaward to the subrecipients. Cause – The District has not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients was not included due to the lack of policies and procedures. Recommendation – The District should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332. Response – The subaward for this grant agreement will have elements specified in the respective agreement as required by Uniform Guidance, Part 200.332. Conclusion – Response accepted.