Finding Text
Condition: During our review of subrecipient agreements, we noted that several agreements did not include the assistance listing title and number required by 2 CFR 200.332(b)(1). Criteria: Per 2 CFR 200.332(b)(1), pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and must include specified information in the subaward agreement. Required elements include, among others, the Federal award identification (e.g., Assistance Listing number, award name, Federal agency), period of performance and indirect cost rate. Cause: The Organization has not established a formal process to ensure that all required elements of 2 CFR §200.332 are included in subrecipient agreements. Effect: Failure to include required elements in subrecipient agreements increases the risk that subrecipients are not fully aware of their responsibilities under Federal awards, which could result in noncompliance with Federal requirements. In addition, the Organization is not in compliance with Uniform Guidance requirements for pass-through entities. Questioned Costs: None determined Recommendation: We recommend that the Organization update its subrecipient agreement templates and contract review procedures to ensure that all required elements under 2 CFR §200.332 are included in each agreement. A compliance checklist should be developed and used during the drafting and execution of agreements to verify completeness. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding; see corrective action plan.