Finding 1116977 (2024-005)

Significant Deficiency Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-03-28

AI Summary

  • Core Issue: The Department lacks adequate internal controls for subrecipient monitoring, leading to compliance challenges.
  • Impacted Requirements: Non-compliance with 2 CFR Part 200 regarding risk assessments and monitoring activities for subrecipients.
  • Recommended Follow-up: Improve documentation processes and ensure timely risk assessments and monitoring activities for all subrecipients.

Finding Text

2024-005 SUBRECIPIENT MONITORING Federal Agency: U.S. Department of Homeland Security/FEMA Federal Program Title & Assistance Listing Number: Disaster Grants – Public Assistance (Presidentially Declared Disasters) - 97.036 Emergency Management Performance Grants – 97.042 Homeland Security Grant Program – 97.067 Award Period: Various Type of Finding:Significant Deficiency in Internal Control over Compliance Other Non-compliance Condition: During our testing, we noted the Department did not have adequate internal controls in place to ensure compliance with subrecipient monitoring. . ALN 97.036, ALN 97.042, ALN 97.067 The Department lacked an effective process to timely provide documentation to the auditors which would evidence compliance with the Subrecipient Monitoring compliance requirement. This makes it difficult for management to monitor for compliance or for a third party to test compliance. All requested documentation was ultimate provided. ALN 97.036 o We reviewed files for 5 subrecipients, from which there were 16 ongoing projects during fiscal year 2024. Of these, 1 of 5 subrecipients did not have evidence that a risk assessment was performed. 2 of 5 subrecipients did not have adequate documentation of monitoring activities performed, including the Department's monitoring checklist. Management's Progress for Repeated Finding: Management made some progress in the performing of risk assessments and reviews of audits for non-disaster grants, but still has opportunity to improve controls in the areas described above. Criteria: According to §200.332 Requirements for pass-through entities of 2 CFR Part 200, 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. In addition, the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass- through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by §200.521 Management Decision. Department Policy No. GRA 418 Sub-Grant Recipient Monitoring effective June 30, 2017 establishes and implements policy and procedures for the Department staff engaged in the Department's sub- grant recipient monitoring process. For Mitigation Sub-Grant Monitoring, the Mitigation Specialist shall review the local progress quarterly reports due to the Department. For Non-Disaster Sub-Grant Recipient Monitoring, the Program Manager shall review the local progress quarterly reports due to the Department. Specific to Pre-Monitoring Requirements and Considerations, Department Program Staff shall perform risk-based assessments and apply the assessment to all of the Department's approved sub-recipients for monitoring purposes and risk designation.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 540529 2024-004
    Material Weakness Repeat
  • 540530 2024-004
    Material Weakness Repeat
  • 540531 2024-004
    Material Weakness Repeat
  • 540532 2024-004
    Material Weakness Repeat
  • 540533 2024-005
    Significant Deficiency Repeat
  • 540534 2024-005
    Significant Deficiency Repeat
  • 540535 2024-005
    Significant Deficiency Repeat
  • 540536 2024-006
    Significant Deficiency
  • 540537 2024-006
    Significant Deficiency
  • 540538 2024-007
    -
  • 1116971 2024-004
    Material Weakness Repeat
  • 1116972 2024-004
    Material Weakness Repeat
  • 1116973 2024-004
    Material Weakness Repeat
  • 1116974 2024-004
    Material Weakness Repeat
  • 1116975 2024-005
    Significant Deficiency Repeat
  • 1116976 2024-005
    Significant Deficiency Repeat
  • 1116978 2024-006
    Significant Deficiency
  • 1116979 2024-006
    Significant Deficiency
  • 1116980 2024-007
    -

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $149.18M
97.039 Hazard Mitigation Grant $58.14M
97.067 Homeland Security Grant Program $6.23M
97.042 Emergency Management Performance Grants $5.22M
97.008 Non-Profit Security Program $630,343
97.047 Bric: Building Resilient Infrastructure and Communities $440,909
20.703 Interagency Hazardous Materials Public Sector Training and Planning Grants $111,785
97.023 Community Assistance Program State Support Services Element (cap-Ssse) $65,001
14.218 Community Development Block Grants/entitlement Grants $38,841