Finding Text
2024-006 Subrecipient Monitoring
Federal Programs – AL 93.569 – Community Services Block Grant (CSBG)
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)). This includes the review of independent audits of subrecipients and
response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes
requiring all subawards granted to subrecipients have specific identifications with the award to
ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition – For the year ended December 31, 2024, we reviewed CAPND's subrecipient
monitoring policy, requested supporting documentation for monitoring activities included, and
interviewed key members of management when documentation was not available. Performance
of several of the policies noted as required under Uniform Guidance for subrecipient monitoring
and per CAPND's internal policies could not be substantiated or were determined to not have
occurred during the year under audit.
Cause – There was missing required information on subawards granted to subrecipients.
Context– Of the total federal expenditures under the program noted above, $283,852 are
passed through to subrecipients. The following are specific items noted that were not in
compliance with the criteria listed above:
We requested copies of all subawards awarded to subrecipients. Of the five subawards
awarded to pass-through entities for the grant year October 2023 to September 2024, all
five were missing the following required information under (2 CFR Section 200.331(a)):
o Subrecipient's unique entity identifier.
o Amount of federal funds obligated by this action by the pass-through entity to the
subrecipient. Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Question costs – None.
Repeat Finding – This is a repeat finding.
Recommendation – The entity should include all required information as determined in CFR
Section 200.331(a) in all subawards.
Views of Responsible Officials – Management recognized the deficiency and plans to implement
the auditor’s recommendation.