Finding 1131217 (2023-004)

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Requirement
M
Questioned Costs
-
Year
2023
Accepted
2025-04-11

AI Summary

  • Core Issue: The Center failed to include required information in all 7 sub-awards to subrecipients, particularly the Assistance Listing Number (ALN).
  • Impacted Requirements: Compliance with 2 CFR 200.332, which mandates that pass-through entities provide specific details in sub-awards to ensure subrecipients understand their federal funding obligations.
  • Recommended Follow-Up: The Center should implement a review process for contracts to ensure all future sub-awards meet the necessary criteria outlined in the Uniform Guidance.

Finding Text

Adult Education-Basic Grants to States-ALN #84.002; U.S. Department of Education; Pass-Through Entity – Pennsylvania Department of Education Criteria: 2 CFR 200.332 states that all pass-through entities must ensure that every sub-award is clearly identified to the subrecipient as a sub-award and includes the following information at the time of the sub-award and if any of these data elements change include the changes in subsequent sub-award modification. When some of this information is not available, the passthrough entity must provide the best information available to describe the Federal award and sub-award. Required information includes: Federal Award Identification which includes: (i) subrecipient name; (ii) subrecipient's unique entity identifier; (iii) Federal Award Identification Number; (iv) Federal Award Date; (v) Sub-award Period of Performance Start and End Date; (vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current obligation; (viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act; (x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xi) Assistance Listing Number (ALN) and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; (xii) Identification of whether the award is R&D and (xiii) Indirect cost rate for the Federal award. Condition: The Center receives federal money to provide Adult Basic Education, General Education Development (GED), family literacy, career assessment and career and job-skills training for the underprivileged of the community. In order to carry out those services, the Center enters into sub-awards with providers throughout its service territory. A review of 7 sub-awards that were deemed to be subrecipients disclosed that all 7 sub-awards did not contain the required information that is to be identified to subrecipients, particularly the ALN. Context: The Center has been providing Adult Basic Education, General Education Development (GED), family literacy, career assessment and career and job-skills training for the underprivileged of the community services under a grant received from the Pennsylvania Department of Education In order to provide the services, sub-awards are made with providers within the Center’s service territory. The sub-awards are required to have certain information disclosed so the subrecipient can comply with the applicable compliance requirements from the funding source. Cause: The Center did not have a process in place to ensure that all sub-awards to subrecipients were reviewed to ensure all required information was included in the agreement. Effect: The subcontractor may have been unaware they were receiving federal funds. As such providers may have been unaware of the applicable compliance requirements. Questioned Costs: None. Repeat Finding: This was not a repeat finding. Recommendation: We recommend the Center review its contracts against the criteria set forth in the Uniform Guidance to ensure that all sub-awards in the future contain the required information for subrecipients. View of Responsible Officials: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.

Categories

Subrecipient Monitoring Period of Performance Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.002 Adult Education - Basic Grants to States $209,500
17.270 Reentry Employment Opportunities $166,313
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $9,625