Finding 1155342 (2024-003)

2024-003 - Subrecipient Monitoring Finding Type. Immaterial Noncompliance / Significant Deficiency in Internal Control over Compliance (Subrecipient Monitoring). Program. Homeland Security Grant Program; U.S. Department of Homeland Security; ALN 97.067; Passed through the Michigan State Police; Award numbers EMW-2022-SS-00031-S01 and EMW-2023-SS-00022-S01. Coronavirus State and Fiscal Recover Funds; U.S. Department of Treasury; ALN 21.027. Criteria. A pass-through entity must monitor the activities of the subrecipients 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 (2 CFR 200.331(d)-(f)), plus any additional items identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award. Condition. We noted that the County did not compile any risk assessments or perform adequate subrecipient monitoring during the fiscal year. Cause. The cause of this condition appears to be a lack of understanding of the subrecipient monitoring requirements of the grants. Effect. The lack of monitoring failed to provide reasonable assurance that the subrecipients complied with the provisions of the grant. Questioned Costs. No costs were questioned due to the fact that the County approved subrecipient expenditures. Recommendation. We recommend that the County create a subrecipient policy to ensure that all subrecipient grant awards are monitored in compliance with the Uniform Guidance requirements. View of Responsible Officials. We concur with the audit assessment regarding this matter.