Finding Text
Condition: During our review of the Head Start grant subrecipient monitoring procedures, the Organization was unable to provide documentation to support that monitoring activities were performed for one of the three subrecipients tested during the audit period. Criteria: In accordance with the Uniform Guidance (2 CFR §200.332(d)), pass-through entities are required to monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes and in compliance with applicable laws, regulations, and the terms and conditions of the subaward. Cause: The Organization did not provide documentation to demonstrate that subrecipient monitoring was performed. As a result, it is possible that the required monitoring activities were not conducted during the audit period, or, if they were performed, they were not adequately documented or retained in accordance with federal grant requirements. Effect: Failure to conduct subrecipient monitoring increases the risk that subrecipients may not be complying with federal program requirements, potentially leading to misuse of federal funds, lack of program quality assurance, or uncorrected deficiencies in service delivery. Recommendation: We recommend that the Organization ensure all required subrecipient monitoring activities are performed in accordance with federal guidelines. Additionally, all monitoring procedures—including risk assessments, site visits, performance reviews, and follow-up actions—should be clearly documented and retained to demonstrate compliance with grant requirements.