Finding Text
Criteria: In accordance with 2 CFR 200.332(d), recipients of federal awards who pass funds to subrecipients are required to monitor the activities of subrecipients to ensure that the subaward is used for authorized purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward. Required monitoring includes reviewing financial and performance reports, following up on deficiencies, and ensuring timely corrective action is taken. Condition: During the year ended December 31, 2024, FFT passed CSLFRF funds to one subrecipient. FFT did not perform any documented monitoring activities over this subrecipient. Specifically, FFT did not obtain or review financial and performance reports, nor did it conduct site visits, desk reviews, or other monitoring procedures required to ensure compliance with federal regulations. Cause: FFT did not establish formalized subrecipient monitoring procedures for CSLFRF funds, due in part to a misunderstanding of its responsibilities as a pass-through entity and the federal compliance requirements related to subrecipient oversight. Effect: As a result of inadequate subrecipient monitoring, there is an increased risk that subrecipients may have expended federal funds on unallowable costs or failed to comply with CSLFRF program requirements. This deficiency exposes FFT to potential repayment of funds and reputational risk if noncompliance is identified at the subrecipient level. Questioned Cost: No specific questioned costs were identified; however, the total amount of CSLFRF funds passed through to the subrecipients without adequate monitoring was $353,050, which is considered to be at risk of noncompliance. Recommendation: We recommend that FFT establish and implement formal subrecipient monitoring procedures to ensure compliance with 2 CFR 200.332(d). This should include, developing a documented monitoring plan for CSLFRF subrecipients, obtaining and reviewing periodic financial and performance reports from subrecipients, performing documented follow-up on any deficiencies noted, and providing training to responsible staff regarding subrecipient monitoring requirements. Views of Responsible Officials: See 2024 Corrective Action Plan.