Finding Text
Criteria: Subrecipient Monitoring - Non-profit entities must follow the requirements for pass-through entities set out at 2 CFR part 200.332. Condition: Lack of documentation of subrecipient monitoring including whether the subrecipient is disqualified. Also, there was no indication of notification of the federal award identification number and amount of federal funds to the subrecipients. Cause: Due to no previous single audit requirement, the Organization has not established a policy of documenting subrecipient monitoring performed or the communication of the federal award identification number and amount of federal funds to subrecipients. Effect: The Organization does not have adequate documentation evidencing subrecipient monitoring procedures were performed or that all required information relating to federal awards was provided to subrecipients. Context: A sample of three disbursements totaling $113,418 were tested from a population of eight transactions totaling $353,835. Questioned costs: No known or likely questioned cost in excess of $25,000. Repeat Finding: No Recommendation: We recommend the Organization establish a formal methodology for documenting subrecipient monitoring and adhere to its policies for communicating federal award identification in accordance with 2 CFR 200.332. Views of responsible officials of the auditee: The Organization concurs with the finding and will implement the following: Develop additional policies and procedures that require documentation of subrecipient monitoring for each subrecipient Ensure all federal subrecipient contracts to include federal award identification number and the amount of federal funds awarded to each subrecipient Distribute policies and procedures and contract templates to all applicable finance and programmatic staff Train staff on the new policies and procedures