Finding Text
Finding 2024-001 – U.S. Department of the Treasury – COVID-19 Justice Advisory Council Gun Violence Prevention and Reduction Program, 21.027
MATERIAL WEAKNESS – SUBRECIPIENT MONITORING
Compliance Requirement: Subrecipient Monitoring
Criteria: As defined in 2 CFR section 200.332, a pass-through entity (“PTE”) must document the risk assessment of each subrecipient and document monitoring activities performed.
Condition: Documentation to evidence compliance with federal regulations related to performing risk assessment of subrecipient and performing certain monitoring activities could not be substantiated.
Cause: Lack of formal written documentation to evidence subrecipient risk assessment and monitoring activities were performed.
Effect: CCSJJC has not implemented appropriate internal controls to ensure the appropriate subrecipient monitoring activities for each subrecipient are performed.
Questioned Costs: None
Context: CCSJJC is obtaining and reviewing subrecipient expenditures to determine that expenditures are allowable under compliance requirements. However, we were unable to substantiate that formal written procedures related to evaluating the fraud risk and risk of noncompliance, and procedures related to monitoring of subrecipients, including review of financial statements and review of audit findings, were performed.
Recommendation: We recommend that CCSJJC implement an internal control to ensure risk assessment and monitoring procedures are performed and formal written documentation is maintained that evidences its compliance with required subrecipient monitoring activities in accordance with 2 CFR 200.
Management’s Response: Due to this being the first Single Audit CCSJJC had encountered and the fact that we were not required to provide certain documentation regarding federal guidelines as a whole, CCSJJC will accept the find. CCSJJC will consider the finding and its content and submit a Corrective Action Plan to cure this finding. We will also take this finding as future guidance in the negotiation process with subrecipients, both from a federal and state perspective to ensure full compliance is achieved.