Finding 1095204 (2024-002)

Criteria or Specific Requirement: 2 CFR section 200.332(b) requires pass-through entities to provide subrecipients with a subaward agreement and ensure that every subaward is clearly identified to the subrecipient as a subaward and provide specific information as outlined at 2 CFR section 200.332(b)(1) through (6). Condition: Internal controls over subrecipient monitoring do not appear to be effective. Testing procedures revealed that there was no subaward agreement provided to the subrecipient of grant funding. Context: There was only one subrecipient for this grant and there was no documentation of a subaward agreement being provided to the subrecepient. Questioned Costs: None Effect: The subrecipient may not have all of the required information that it needs for its own Uniform Guidance audit. In addition, the subrecipient may not be aware of the applicable laws and regulations as well as the specific compliance requirements as they relate to the funding they are receiving from the District. Cause: Because the subrecipient was involved with the application process and subsequent communications with the District as well as the Wisconsin Department of Workforce Development, the District thought the subrecipient had all of the required information and therefore didn't issue a formal subaward document. Repeat: No Auditor's Recommendation: We recommend that the District review its polices and procedures related to subrecipient monitoring. View of Responsible Officials: The finding is acknowledged. The District will provide a subaward agreement to the current subrecipient and has put in place the required subaward agreement on future federal grants with subrecipients to ensure compliance with the Uniform Guidance requirements.