Finding 1157582 (2024-003)

Subrecipient Monitoring U.S. Department of Health and Human Services Special Programs For The Aging, Title III, Part C, Nutrition Services – ALN #93.045 Criterion: Per CFR 200.331 the grantee must monitor the activities of the subrecipient 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. Per CFR 200.303, a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The County passed through funding to nine subrecipients totaling $3,434,144. During 2024, management did not properly monitor the subrecipients. Specifically, for the nine of the nine subrecipients management was unable to provide any documented evidence of a monitoring being performed although the contract periods are ongoing for all nine subrecipients. Cause and Effect: Management lacks a process to ensure that the monitoring of subrecipients is occurring during the contract period, and evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Therefore, subrecipients were not properly monitored in accordance with 2 CFR 200.331 nor in accordance with the County’s Subrecipient Monitoring Policy. Questioned Cost: None Recommendation: We recommend that management enhance the design of its control activities to ensure that subrecipient files are adequately maintained, and perform risk assessment evaluations on all subrecipients to ensure they are effectively monitored during the contract period noted in the contractual agreements and the County’s Subrecipient Monitoring Policy. View of Responsible Officials: The Department of Senior Services agrees with this finding. Senior Services follows the monitoring standards established by the pass-through entity. However, the Department has implemented process improvements to ensure that all Program Year 2024_2025 compliance processes were met. The current period monitoring plan, risk assessments and monitoring have been completed. The Department will maintain an annual monitoring plan to ensure that all subrecipients are monitored in compliance with 2 CFR200 requirements.