Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria: 2 CFR section 200.332(a) requires pass-through entities to ensure every subaward is clearly
identified to the subrecipient as a subaward and includes the required federal award identification
information, all requirements imposed by the pass-through entity on the subrecipient, any additional
requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a requirement that
the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records
and financial statements, and appropriate terms and conditions concerning the closeout of the subaward.
2 CFR section 200.332(b) requires the pass-through entity to evaluate each subrecipient’s risk of
noncompliance with federal statutes, regulations, and the terms and conditions for determining appropriate
subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through entity to monitor the activities of the subrecipient 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 the subaward performance
goals are achieved. 2 CFR section 200.332(f) requires the pass-through entity to verify that every
subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient’s
federal awards expended during the respective fiscal year equaled or exceeded $750,000.
Condition: No subaward agreements included all required information. No risk assessments were
performed and documented. No monitoring procedures were performed other than reviewing invoices to
be paid and an audit report received.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify and document whether subrecipients that expended
$750,000 or more in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Subrecipients may not be in compliance with the terms and conditions of the
award and costs charged may be unallowable and disallowed.
Repeat Finding: This is a repeat of Finding 2022-003.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed,
implemented, and documented within the subrecipient monitoring procedures to ensure compliance with 2
CFR section 200.332. Subrecipient monitoring activities should be performed and documented.
Views of Responsible Officials: Management agrees with the finding and will implement procedures.