Finding 1115958 (2024-003)

Significant Deficiency
Requirement
M
Questioned Costs
$1
Year
2024
Accepted
2025-03-28

AI Summary

  • Core Issue: The Board failed to document monitoring procedures for subrecipients, violating federal compliance requirements.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303 and 2 CFR 200.332(b) regarding subrecipient monitoring and risk assessment.
  • Recommended Follow-Up: Implement new policies and ensure proper personnel are assigned to monitor subrecipients effectively.

Finding Text

2024-003 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name Federal Assistance Listing Number U.S. Department of Labor WIOA Cluster 17.258/17.259/17.278 Criteria: 2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Recipients must ensure that commercial organizations that are subrecipients under WIOA Title I and expend more than the minimum level specified in 2 CFR Part 200, Subpart F, have either an organization-wide audit conducted in accordance with 2 CFR Part 200 or a program-specific financial and compliance audit (20 CFR section 683.210). 2 CFR 200.332(b) requires that 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 described in paragraphs (d) and (e) of this section. Condition: The Board did not maintain documentation of monitoring procedures performed on its subrecipient during the fiscal year ended June 30, 2024. The Board obtained the subrecipient’s audit report; however documentation of review of the audit report and risk assessment procedures performed on the subrecipient were not maintained as evidence of subrecipient monitoring performed. Questioned Costs: Unknown Context: Total federal expenditures for the WIOA Cluster were $1,377,447 for the year ended June 30, 2024, which included $293,830 of expenditures to subrecipients. Cause: The Board adopted policies and procedures surrounding the subrecipient monitoring compliance requirements in February 2025; however, no documented evidence of subrecipient monitoring completed during the fiscal year ended June 30, 2024 could be provided. Effect: The Board is not in compliance with the federal statutes, regulations, and terms and conditions of the federal award. Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Views of Responsible Officials: We agree with the finding and will take the necessary corrective actions as noted in the corrective action plan attached.

Categories

Questioned Costs Subrecipient Monitoring

Other Findings in this Audit

  • 539502 2024-001
    Significant Deficiency Repeat
  • 539503 2024-001
    Significant Deficiency Repeat
  • 539504 2024-001
    Significant Deficiency Repeat
  • 539505 2024-001
    Significant Deficiency Repeat
  • 539506 2024-001
    Significant Deficiency Repeat
  • 539507 2024-001
    Significant Deficiency Repeat
  • 539508 2024-001
    Significant Deficiency Repeat
  • 539509 2024-002
    Significant Deficiency
  • 539510 2024-002
    Significant Deficiency
  • 539511 2024-002
    Significant Deficiency
  • 539512 2024-002
    Significant Deficiency
  • 539513 2024-002
    Significant Deficiency
  • 539514 2024-002
    Significant Deficiency
  • 539515 2024-002
    Significant Deficiency
  • 539516 2024-003
    Significant Deficiency
  • 539517 2024-003
    Significant Deficiency
  • 539518 2024-003
    Significant Deficiency
  • 539519 2024-003
    Significant Deficiency
  • 539520 2024-003
    Significant Deficiency
  • 539521 2024-003
    Significant Deficiency
  • 539522 2024-003
    Significant Deficiency
  • 539523 2024-004
    Significant Deficiency
  • 539524 2024-004
    Significant Deficiency
  • 539525 2024-004
    Significant Deficiency
  • 539526 2024-004
    Significant Deficiency
  • 539527 2024-004
    Significant Deficiency
  • 539528 2024-004
    Significant Deficiency
  • 539529 2024-004
    Significant Deficiency
  • 1115944 2024-001
    Significant Deficiency Repeat
  • 1115945 2024-001
    Significant Deficiency Repeat
  • 1115946 2024-001
    Significant Deficiency Repeat
  • 1115947 2024-001
    Significant Deficiency Repeat
  • 1115948 2024-001
    Significant Deficiency Repeat
  • 1115949 2024-001
    Significant Deficiency Repeat
  • 1115950 2024-001
    Significant Deficiency Repeat
  • 1115951 2024-002
    Significant Deficiency
  • 1115952 2024-002
    Significant Deficiency
  • 1115953 2024-002
    Significant Deficiency
  • 1115954 2024-002
    Significant Deficiency
  • 1115955 2024-002
    Significant Deficiency
  • 1115956 2024-002
    Significant Deficiency
  • 1115957 2024-002
    Significant Deficiency
  • 1115959 2024-003
    Significant Deficiency
  • 1115960 2024-003
    Significant Deficiency
  • 1115961 2024-003
    Significant Deficiency
  • 1115962 2024-003
    Significant Deficiency
  • 1115963 2024-003
    Significant Deficiency
  • 1115964 2024-003
    Significant Deficiency
  • 1115965 2024-004
    Significant Deficiency
  • 1115966 2024-004
    Significant Deficiency
  • 1115967 2024-004
    Significant Deficiency
  • 1115968 2024-004
    Significant Deficiency
  • 1115969 2024-004
    Significant Deficiency
  • 1115970 2024-004
    Significant Deficiency
  • 1115971 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
17.258 Wia/wioa Adult Program $287,824
17.278 Wia/wioa Dislocated Worker Formula Grants $168,069
17.259 Wia/wioa Youth Activities $111,886
10.561 Supplemental Nutrition Assistance Program $76,363
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $71,576