Finding 1156977 (2024-001)

Finding 2024-001 – Internal Control Over Compliance, Material Noncompliance - Subrecipient Monitoring (Material Weakness) - Repeated (Prior Year Finding 2023-002) Information on the Major Programs Affected Funding Agency Title Federal Assistance listing number U.S. Department of Education Humboldt Bay Youth Community Project 84.299A Criteria In accordance with the Uniform Guidance Section 200.332(b), 200.332(d), and 200.332(f), Requirements for Pass-Through Entities, pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Pass-through entities must also monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include; (1) reviewing financial and performance reports required by the pass-through entity; (2) following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and other means; and (3) issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity. Additionally, pass-through entities must verify that every subrecipient is audited as required by Subpart F – Audit Requirements when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 200.501. Condition/Context During our testing of subrecipient monitoring, the Tribe was unable to provide documentation for any of the subrecipients indicating that a formal risk assessment had been conducted. Cause The Tribe has not implemented sufficient internal controls or monitoring procedures to oversee the subrecipient’s activities effectively. Effect The Tribe is not in compliance with federal requirements related to subrecipient monitoring. Recommendation We recommend that the Tribe implement the necessary internal controls to ensure effective subrecipient monitoring through risk assessments. The Tribe should establish comprehensive procedures to identify all subrecipient expenditures that correspond to federal grants.