Finding Text
Federal program: All federal awards provided to subrecipients.
FY/Federal Award ID#: FY2024/All federal awards provided to subrecipients.
Federal agency: All federal awards provided to subrecipients.
Pass thru entity: All federal awards provided to subrecipients.
Criteria: per 24 CFR 574.500 -- Responsibility for grant administration:
(a) General. Grantees are responsible for ensuring that grants are administered in accordance with the requirements of this part and other applicable laws. Grantees are responsible for ensuring that their respective subrecipients carry out activities in compliance with all applicable requirements.
(b) Grant agreement. The grant agreement will provide that the grantee agrees, and will ensure that each subrecipient agrees, to:
(1) Operate the program in accordance with the provisions of these regulations and other applicable HUD regulations;
(2) Conduct an ongoing assessment of the housing assistance and supportive services required by the participants in the program;
(3) Assure the adequate provision of supportive services to the participants in the program; and
(4) Comply with such other terms and conditions, including recordkeeping and reports (which must include racial and ethnic data on participants) for program monitoring and evaluation purposes, as HUD may establish for purposes of carrying out the program in an effective and efficient manner. And 24 CFR 574.500 Applicability of Uniform Administrative Requirements as per 2 CFR 200.332(f) Requirements for pass-through entities. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in §200.501.
Condition: The Foundation is not in compliance with recordkeeping for program monitoring and evaluation, as the Foundation did not comprehensively asses all subrecipients using riskbased/ subrecipient monitoring policies and procedures.
Questioned Costs: None noted.
Cause: Staff were not aware of the extent of the requirements to monitor program and fiscal compliance of project sponsors and document results and evidence of compliance or non-compliance. Therefore, a number of project sponsors/subrecipients were not monitored.
Effect: Granting agencies cannot determine whether the Foundation is ensuring that the project sponsor is carrying out activities in compliance with all applicable requirements.
Recommendation: The Foundation provide written policies and procedures for project sponsor monitoring and oversight, create a risk analysis form/process for all funded project sponsors and create a timeline to monitor project sponsors based on the risk analysis completed.
Views of Responsible Officials: The Foundation has updated its Quality Management Plan to include comprehensive subrecipient monitoring policies. The Quality Management team is working with all programming to implement a robust monitoring process, including risk assessments, adherence to grantor regulations, service delivery, and program outcomes.