Finding Text
Criteria: Per 2 CFR 200.332, pass-through entities must evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward, and monitor subrecipient activities to provide reasonable assurance that the subaward is used for authorized purposes and in compliance with applicable requirements. Condition: The Organization did not consistently document and retain required monitoring procedures and assessments performed. Cause: The Organization had not developed policies and procedures to ensure compliance with subrecipient risk assessment and monitoring requirements. Effect: The Organization did not comply with 2 CFR 200.332. The lack of effective processes and documentation increases the risk of noncompliance by subrecipients, potential misuse of Federal funds, and questioned costs that could adversely affect current and future Federal funding. Questioned Costs: $0 Recommendation: We recommend the Organization strengthen its internal control framework over subrecipients by developing and implementing written policies and procedures for consistently performing and documenting risk assessments prior to making subawards, establishing clear monitoring protocols such as periodic report reviews, site visits, and follow-up on identified issues, and maintaining evidence of all monitoring activities performed. These steps will help ensure compliance with 2 CFR 200.332, reduce the risk of subrecipient noncompliance, and provide assurance that Federal funds are used for their intended purposes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Organization hired a new Executive Director in the fall of 2024 and has discussed the matter with the Department of Agriculture and legal counsel to ensure compliance requirements are followed.