Finding Text
2023-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance
Federal Program: Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury, Pass Through Entity Identifying Number: Not Available
Assistance Listing #21.023, Emergency Rental Assistance Program, U.S. Department of Treasury, Passed through the Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: N/A
Prior Year Finding Number 2022-004
Criteria: The requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (Uniform Guidance), §200.331 Requirements for Pass-through Entities, requires entities who pass federal funding through to subrecipients evaluate each subrecipient's risk of noncompliance. As detailed in 2 CFR sections 200.331(d) through (f), the Uniform Guidance requires pass-through entities to monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. This includes issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient, as detailed in 2 CFR section 200.521.
Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over its subrecipients in compliance with the Uniform Guidance.
Questioned Costs: N/A
Cause: While the County has monitoring processes in place for subrecipients, it is not currently documenting certain of the initial risk assessment decisions or the occurrence of ongoing monitoring activities for its subrecipient, representing a significant deficiency in internal control over compliance.
Effect: The County is not in compliance with certain requirements of the Uniform Guidance.
Recommendation: We recommend that County management perform and document the various monitoring activities performed with regard to its subrecipients.
Views of Responsible Officials and Planned Corrective Actions: Management understands and is working to provide better oversight and monitoring of entities that receive pass-through grant dollars. See corrective action plan.