Finding Text
Finding Number: 2021-005; Finding Type: Federal award finding; Federal Assistance Listing No.: 93.665; Pro-gram Name: COVID -19 Emergency Grants to Address Mental and Substance Use Disorders During COVID-19; Federal Agency: U.S. Department of Health and Human Services; Pass-Through Entity: Oregon Health Authority; Grant Number: 167045; Federal Award Year: 2021; Control Deficiency Type: Significant deficiency in internal controls over compliance; Instance of Noncompliance: Yes; Compliance Requirement: Subrecipient monitoring; Questioned Costs: None; Repeat Finding: No;
Criteria: In accordance with the requirements of 2 CFR §200.332, a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes all the required information at the time of the subaward so that federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award.
Condition: The Coalition did not include all of the required information in the subawards granted to subre-cipients. Information missing from the subaward grant agreements includes the following: Subrecipient unique entity identifier; Federal award date; Total amount of federal funds obligated to subrecipient including the current award; Name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; Assistance listings 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 disburse-ment; Indirect cost rate for the federal award (including if the de minimis rate is charged) per § 200.414; All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in ac-cordance with federal statutes, regulations and the terms and conditions of the federal award.
Cause: The coalition was unaware of the subaward requirements of CFR §200.332.
Effect: The Coalition did not comply with CFR §200.332.
Audit Recommendation: We recommend that management implement procedures to ensure that all subawards contain the information required by CFR §200.332.
Management’s Response: The Coalition will ensure that all future federal subawards will contain the infor-mation required by CFR §200.332. All contracts, sub-grantees, and MOUs, will include information required.