Finding Text
Finding 2023-004: Subrecipient Management and Monitoring (Material Weakness)
Information on the Federal Programs: Assistance Listing Number 98.001
Criteria: As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each
subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of
the subaward for purposes of determining the appropriate subrecipient monitoring procedures to
prescribe to each individual subrecipient.
Condition: Astraea has a subaward policy, which requires a risk assessment form be completed for
each potential subrecipient. However, this step was not completed for all of the subrecipients in which
Astraea engaged with during the fiscal year.
Cause: Astraea did not adhere to its policy in regards to risk assessment procedures.
Context: Astraea failed to perform risk assessment procedures. Our audit work in this area consisted
of substantive testwork over a sample of subrecipient expenditures that were selected based on a
defined threshold. We consider our sample to be representative of the populations, and thus, is a
statistically valid sample. The issue is deemed to be systemic.
Effect: Astraea could inadvertently engage in relationships with subrecipients of higher risk without the
appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in
accordance with the provisions and terms of the subaward.
Questioned Costs: None noted.
Identification as a Repeat Finding, if Applicable: Finding 2022-004
Recommendation: We recommend Astraea adhere to its current subaward policy and ensure the risk
assessment procedures over all of its subrecipients are performed and documented prior to
engagement. Based on these risk assessments, Astraea should assign a risk level to each, and then
determine the monitoring tools to apply based on these risk levels. We also recommend Astraea
require its subrecipients to submit financial reports demonstrating use of each advance before
advancing more funds, to ensure subrecipients are expending funds appropriately.