Finding 1094770 (2023-004)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2025-01-08
Audit: 336686
Organization: Community Action Team, Inc. (OR)

AI Summary

  • Core Issue: CAT lacks documented procedures for monitoring subrecipients, risking non-compliance with federal requirements.
  • Impacted Requirements: Non-compliance with 2 CFR sections 200.303 and 200.332 regarding internal controls and risk assessment for federal awards.
  • Recommended Follow-up: Establish and enforce written policies for subrecipient monitoring and ensure compliance with Uniform Guidance requirements.

Finding Text

2023-004 Finding – Federal Award Type: Subrecipient Monitoring – Material Non-Compliance and Material Weakness in Internal Control over Compliance) Identification of Federal Program: AL Number: 64.033 Supportive Services for Veteran Families Criteria / Requirement: 2 CFR section 200.303 requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In accordance with 2 CFR section 200.332, a pass-through entity must clearly identify to the subrecipient the award as a subaward by providing the required federal information related to the award, and 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 provisions of contracts and grants agreements. The pass-through entity must evaluate risk of non-compliance of each subrecipient, monitoring the subrecipient and ensuring accountability of for-profit subrecipients. Per 2 CFR 200.332(d)(2) & (3), an entity must ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, highlighting the status of action planned or taken to address Single Audit Finding related to the subaward. Further, they must issue a management decision for applicable audit findings. Condition / Context: CAT passed through $486,835 in funding to subrecipients under AL number 64.033. It was noted during the audit that CAT did not have documented written procedures or controls in place to ensure compliance with Uniform Guidance Subrecipient Monitoring requirements. Condition / Context (Continued): It was noted that within subaward contracts, required federal contract information was provided. Additionally, CAT is having regular meetings to ensure tasks are being completed in a timely manner and providing technical assistance when needed. However, for the one subrecipient tested out of three, there was no documentation of risk assessment of the subrecipient entity and no formal monitoring of the entity. The subrecipient tested was subject to 2 CFR Subpart F, Single Audit, and the audit for this entity was not obtained and therefore CAT did not review Single Audit Findings that may be related to the subaward. Cause: Procedures and internal controls were not in place to ensure that CAT is maintaining proper subrecipient monitoring for each federal subrecipient. Effect: Failure to maintain sufficient subrecipient monitoring may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements of the federal award. Questioned Costs: None. Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Management’s Response: Management concurs with the finding and has defined corrective action to address it. Staff have reviewed policies and procedures already in place to ensure compliance of subrecipient monitoring. The Fiscal department has subsequently conducted a fiscal desk review of the subrecipient in question for FY 22/23 and no findings were found. Standard Operating Processes were updated to ensure all subrecipients are fiscally monitored based on the Risk Assessment Determination level. The above identified corrective action was implemented in July 2024. Stacey Wilson, Fiscal Director, has implemented a monitoring calendar for fiscal and Program Director’s will be responsible for ensuring subrecipients are monitored.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 518327 2023-003
    Material Weakness
  • 518328 2023-004
    Material Weakness
  • 518329 2023-002
    Significant Deficiency
  • 1094769 2023-003
    Material Weakness
  • 1094771 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.600 Head Start $2.74M
93.568 Low-Income Home Energy Assistance $924,262
14.267 Continuum of Care Program $911,889
64.033 Va Supportive Services for Veteran Families Program $852,336
10.415 Rural Rental Housing Loans $439,298
81.U01 Bonneville Power Administration Weatherization $207,659
21.023 Emergency Rental Assistance Program $176,813
10.558 Child and Adult Care Food Program $159,710
93.870 Maternal, Infant and Early Childhood Homevisiting Grant Program $137,987
14.247 Self-Help Homeownership Opportunity Program $135,000
93.569 Community Services Block Grant $120,522
81.042 Weatherization Assistance for Low-Income Persons $96,438
93.499 Low Income Household Water Assistance Program $96,222
93.052 National Family Caregiver Support, Title Iii, Part E $90,825
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $81,918
21.019 Coronavirus Relief Fund $59,133
93.558 Temporary Assistance for Needy Families $55,237
10.420 Rural Self-Help Housing Technical Assistance $49,328
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $47,382
93.053 Nutrition Services Incentive Program $42,167
14.169 Housing Counseling Assistance Program $40,642
10.559 Summer Food Service Program for Children $18,305
14.231 Emergency Solutions Grant Program $7,094
93.043 Special Programs for the Aging, Title Iii, Part D, Disease Prevention and Health Promotion Services $1,703
93.041 Special Programs for the Aging, Title Vii, Chapter 3, Programs for Prevention of Elder Abuse, Neglect, and Exploitation $712
10.433 Rural Housing Preservation Grants $288