Finding Text
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 93.600, Department of Health and Human Services, Head Start and Covid-19: Head Start ARP
Federal Award Identification Number and Year: 05CH011937-03-03, 05HE000989-01-01
Pass-through Entity – N/A
Finding Type – Significant deficiency in internal control over compliance
Repeat Finding – No
Criteria – Per 2 CFR 200.332 all pass-through entities must:
(a) 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:
(1) Federal award identification.
(i) Subrecipient name (which must match the name associated with its unique entity identifier);
(ii) Subrecipient's unique entity identifier;
(iii) Federal Award Identification Number (FAIN);
(iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency;
(v) Subaward Period of Performance Start and End Date;
(vi) Subaward Budget Period Start and End Date;
(vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;
(viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation;
(ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
(x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA);
(xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity;
(xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement;
(xiii) Identification of whether the Federal award is for research and development; and
(xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414)
Condition – During our test work, we noted that 3 out of 3 subaward agreements tested did not include the information as noted in 2 CFR 200.332. The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient.
Identification of How Questioned Costs Were Computed – N/A
Questioned Costs – None
Cause/Effect – The controls in place did not ensure that the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, were included in the grant agreement of its subrecipient. As a result, required information was omitted.
Recommendation – We recommend that management review its procedures and controls to ensure the required information as prescribed by 2 CFR 200.332, Requirements for Pass-through Entities, is included in all subawards to subrecipients.
View of Responsible Officials and Corrective Action Plan –The Agency agrees with the finding. When granting funds as a subaward to a pass-through entity, the Agency will update its master templates for subawards to include the required information. In addition, when the sub agreements are routed for signature and reviewed by the Chief Financial Officer, they will be double-checked to ensure compliance with this requirement.