Finding Text
2022-005 Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient
Monitoring - Repeat
Identification of federal
program:
64.033 VA Support Services for Veteran Families Program
Award 20-AK-152
Department of Veterans Affairs
Criteria: Per Part 3 of the Uniform Guidance Compliance Supplement,
A pass-through entity (PTE) must:
- Identify the Award and Applicable Requirements- clearly identify to the
subrecipient: (1) the award as a subaward at the time of subaward (2) all
requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations,
and the terms and conditions of the award.
- Evaluate Risk - evaluate each subrecipient's risk of noncompliance for
the purpose of determining the appropriate subrecipient monitoring
related to the subaward.
- Monitor - monitor the activities of the subrecipient as necessary to
ensure that the subaward is used for authorized purposes, complies
with the terms and conditions of the subaward, and achieves
performance goals.
Condition: In 2021 the Organization was unable to provide documentation that the
evaluation of risk and monitoring of the activities of the subrecipient was
performed.
In fiscal year 2022, the Organization was able to provide invoices
submitted that were reviewed in order for payments to be made to the
subrecipients providing monitoring of the activities of the subrecipients
but still were evaluating the risk related to debarment of the subrecipients.
Cause: The Organization has had turnover in all management positions since the
fiscal year ended March 31, 2021 and into 2022. Prior management did
not maintain complete or accurate files.
Effect or potential effect: The Organization’s current management was unable to provide records
showing that the evaluation of subrecipients was performed.
Questioned Costs: None
Context: The Organization entered into 3 subawards during the period under audit.
The sub awardees were approved in the SSVF program budget by the
federal agency. During the current year the auditor reviewed the
agreements and noted there were no supporting documentation showing
that the Organization had evaluated the risk of the sub awardees.
Identification of Repeat
Finding:
2021-009
Recommendation: We recommend that as a part of the Organization’s internal control
structure over compliance subrecipients that the Organization is entering
into agreements with, they establish procedures to ensure federal
subrecipient risk evaluation is completed and maintained.
Views of Responsible
Officials:
See Corrective Action Plan