Finding Text
Reference Number 2024-004 Subaward Agreements
Federal Awards: GEAR UP (ALN 84.334A)
Criteria and Condition: A pass-through entity must clearly identify to the subrecipient; (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.332(b)(1); (2) 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 terms and conditions of the award; and (3) any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility for the federal award. We noted a formal subaward agreement outlining all the required information is not prepared and executed by the Center (pass-through entity) and its subrecipients. Amended guidance was communicated to the Center as 34 CFR 75.127 through 75.129 was amended on August 29, 2024. Under this new guidance, an agreement that details the activities that each member of the group plans to perform, and binds each member of the group to every statement and assurance made by the application will be required on an ongoing basis. The Center intends to comply with this requirement on an ongoing basis.
Cause and Effect: The Center provides separate documents to its subrecipients such as the District/Campus Commitment Form that outlines some of the applicable compliance requirements and a Program Budget Award Worksheet. A formal subaward agreement executed by both parties containing all the information required by 200.332(b)(1) is not in place. This results in noncompliance with subrecipient monitoring requirements.
Repeat Finding from Prior Year(s): N/A
Questioned Costs: $0
Recommendation: As 34 CFR 75.127 through 75.129 was amended on August 29, 2024, we recommend management implement this guidance and maintain formal agreements between the Center and the subrecipients/partners in the program.
Views of Responsible Officials:
See management’s corrective action plan.