Finding Text
Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters
Federal Agency: U.S. Department of the Treasury
Federal Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), ALN No. 21.027
Compliance Requirement: Subrecipient Monitoring
Repeat Finding: No
Condition: During our testing of five subrecipient awards, we noted that management was not able to provide supporting documentation that monitoring procedures were performed on subrecipients to confirm that they were audited, if determined necessary, after the disbursement of funds by the City.
Questioned Costs: None
Context: For five of five subrecipients tested, management was not able to provide the required support showing that the City checked to make sure the subrecipients were getting an audit, if needed.
Criteria: 2 CFR Part 200, Subpart F requires the pass-through entity to verify that subrecipients expected to be audited met this requirement.
Cause: There was significant turnover within the finance department of the City and grants administration was missing supervision by key personnel.
Effect: Failure to verify and review subrecipient audits could result in subrecipients lacking required audits or not identifying audit findings that directly impact the program’s compliance requirements.
Recommendation: We understand the grants administration has been assigned to a specific department. We recommend that the City have policies in place to make sure that all monitoring of subrecipients is completed in alignment with the Uniform Guidance compliance requirements.