FAC Explorer

Finding 1161548 (2024-003)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-10-29
Audit: 371432
Organization: Pueblo County Colorado (CO)
Auditor: CLIFTONLARSONALLEN LLP

AI Summary

  • Core Issue: Subrecipients are missing critical information in their agreements, such as DUNS numbers and federal award details, which violates federal requirements.
  • Impacted Requirements: Non-compliance with 2 CFR 200.331(a) and 2 CFR 200.303, including lack of risk evaluation and monitoring of subrecipients.
  • Recommended Follow-Up: The County should enhance procedures to ensure all required information is included in subaward documents and establish effective monitoring practices for subrecipients.

Finding Text

Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (ALN) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Reporting requirements from the subrecipients to the County were also not met. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. Five of the five subrecipients were missing an internal checklist that is signed by the County Manager. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2023-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For future awards the County will include compliance requirements to subrecipients in the award documents. For previously issued awards, the County will use appropriate subrecipient monitoring procedures to ensure compliance with the grants awarded throughout the remainder of the contract periods. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2025

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1161539 2024-001
    Material Weakness Repeat
  • 1161540 2024-001
    Material Weakness Repeat
  • 1161541 2024-001
    Material Weakness Repeat
  • 1161542 2024-001
    Material Weakness Repeat
  • 1161543 2024-002
    Material Weakness Repeat
  • 1161544 2024-002
    Material Weakness Repeat
  • 1161545 2024-002
    Material Weakness Repeat
  • 1161546 2024-003
    Material Weakness Repeat
  • 1161547 2024-003
    Material Weakness Repeat
  • 1161549 2024-004
    Material Weakness Repeat
  • 1161550 2024-004
    Material Weakness Repeat
  • 1161551 2024-004
    Material Weakness Repeat
  • 1161552 2024-005
    Material Weakness Repeat
  • 1161553 2024-005
    Material Weakness Repeat
  • 1161554 2024-005
    Material Weakness Repeat
  • 1161555 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance to Needy Families $9.00M
93.568 Low-Income Home Energy Assistance (DSS) $4.09M
93.778 Title XIX, Medicaid Medical Assistance Program $3.84M
93.575 Child Care & Development Block Grant $2.76M
93.658 Foster Care - Title IV-E $2.46M
93.563 Title IV-D, Child Support Services $2.43M
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $2.04M
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES NON-CASH) $1.72M
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $1.32M
93.659 Adoption Assistance $1.22M
81.042 Weatherization Assistance for Low-Income Persons $1.05M
21.027 COVID-19 Coronavirus State and Local Fiscal $1.05M
93.471 Title IV-E Kinship Navigator Program $932,869
93.045 Title III, Part C - Nutrition Services $898,205
93.568 Low-Income Home Energy Assistance (HHS) $634,731
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM (COMMODITIES - NON-CASH) $584,468
93.667 Social Services Block Grant - Title XX $582,816
90.404 HAVA Election Security Grants $551,213
93.044 Title III, Part B - Grants for Supportive Services and Senior Centers $510,878
93.472 Title IV-E Prevention Program $454,898
93.959 Substance Abuse Prevention and Treatment Block Grant $321,830
93.569 Community Services Block Grant $315,199
97.067 Homeland Security Grant $297,659
93.778 Single Entry Point, Medical Assistance Program $198,179
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS $176,829
93.090 Guardianship Assistance $151,493
93.958 Block Grant for Community Mental Health Services $144,829
10.565 COMMODITY SUPPLEMENTAL FOOD PROGRAM (ADMIN) $124,486
93.645 Child Welfare Services-State Grants Title IV-B $107,002
97.042 Emergency Management Performance Grant $91,688
16.738 Edward Byrne Memorial Justice Assistance Grant $82,763
93.674 Chafee Foster Care Independence Program $79,860
93.041 Title VII - Chapter 3 - Programs for Prevention of Elder Abuse, Neglect, and Exploitation $69,167
16.575 Crime Victim Assistance (Sheriff) $60,298
16.606 State Criminal Alien Assistance Program $58,154
93.592 Family Violence Prevention and Services/Discretionary $37,381
93.634 Applied Research in Child Welfare (ARCH) $30,965
16.575 Crime Victim Assistance (DA) $30,600
93.517 Affordable Care Act - ADRC $29,193
93.052 Title III, Part E - National Family Caregiver Support $24,385
21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds $15,298
93.043 Title III, Part D - Disease Prevention and Health Promotion Services $14,781
93.053 Nutrition Services Incentive Program (USDA) $10,584
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (ADMIN) $9,996
16.922 Federal Forfeiture Funds $9,272
93.747 COVID-19 - Elder Abuse Prevention Interventions Program $4,839
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $4,735
16.543 Missing Children's Assistance $4,412
20.616 National Priority Safety Programs $4,121
93.556 Promoting Safe & Stable Families $1,204