Finding Text
Federal Program: Coronavirus State and Local Fiscal Recovery Funds- Assistance Listing Number 21.027 Federal Agency: U.S. Department of Treasury Pass-through Entity: Illinois Department of Human Services Condition: The Organization has not established written procedures to identify, assess risk of, monitor, or accurately track amounts provided to subrecipients of ARPA funding. No subrecipient notification letters were issued to entities receiving subawards, and the Organization could not provide complete and accurate records of the amounts passed through to subrecipients during the audit period. Criteria: 2 CFR §200.331 requires pass-through entities to evaluate subrecipient risk, ensure each subaward is properly identified, issue required subaward notifications, verify suspension/debarment status, monitor subrecipient activities, and ensure subrecipients meet audit requirements. 2 CFR §200.302 further requires non-federal entities to identify, in their accounts, all federal awards received and expended, including amounts provided to subrecipients, to ensure accurate financial reporting and SEFA disclosure. Cause: Lack of formal policies and training regarding pass-through responsibilities under Uniform Guidance. Effect: The Organization cannot demonstrate compliance with federal pass-through requirements. This increases the risk of unallowable costs, subrecipient noncompliance, and misstated SEFA reporting due to the inability to determine and disclose amounts passed through to subrecipients . Questioned Costs: None noted during audit testing. Auditor’s Recommendation: The Organization should adopt written subrecipient monitoring and tracking policies, perform risk assessments, issue subaward notifications with all required elements, and implement procedures to accurately record and disclose the amounts provided to subrecipients in the general ledger and SEFA.