Finding Text
Finding 2024-002: Subrecipient Monitoring - Risk Assessment
Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801
Questioned costs: None.
Criteria: In accordance with 2 CFR 200.332(b), Asian University for Women (AUW) Support Foundation should 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 paragraph (e) of this section, which may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) whether the subrecipient has new personnel or new or substantially changed systems; and (4) the extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).
Condition: During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200.
Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed.
Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b).
Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls.
Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures.
Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan