Finding 1162696 (2024-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-11-19
Audit: 372332
Organization: Town of Southold (NY)

AI Summary

  • Core Issue: The Town failed to execute a formal subrecipient agreement with Fishers Island Ferry District for federal funds, violating 2 CFR § 200.332(a).
  • Impacted Requirements: Lack of a written agreement means the subrecipient may not understand compliance requirements, risking noncompliance and potential misuse of funds.
  • Recommended Follow-Up: The Town should implement procedures to ensure all subrecipient agreements are formalized before disbursing federal funds, including all necessary compliance details.

Finding Text

Criteria In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requirements at the time of subaward, including the Federal award identification, all compliance requirements, and any additional terms and conditions imposed by the pass-through entity. Condition During our audit of the airport improvement program grant awarded to the Town, we noted that the Town did not execute a formal subrecipient agreement with Fishers Island Ferry District, to whom federal funds were passed through during the audit period. Specifically, no written agreement was in place outlining the subrecipient’s responsibilities, applicable compliance requirements, or the terms and conditions of the award. Cause The Town did not have procedures in place to ensure that subrecipient agreements are issued for this program. Effect Without a formal subrecipient agreement, the entity increased the risk that the subrecipient may not fully understand or comply with federal award requirements. This could result in noncompliance with federal regulations, potential misuse of funds, and questioned costs. Additionally, the entity is not in full compliance with Uniform Guidance. Questioned Costs None Recommendation We recommend that the Town develop and implement procedures to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds. These agreements should contain all elements required by 2 CFR § 200.332(a), including the identification of the federal award, applicable compliance requirements, and any additional terms and conditions. Views of Responsible Officials The Town agrees with this finding. The absence of subrecipient agreements for the airport improvement program was an oversight. Procedures have since been put in place to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds.

Corrective Action Plan

Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requirements at the time of subaward, including the Federal award identification, all compliance requirements, and any additional terms and conditions imposed by the pass-through entity. The Town did not execute a formal subrecipient agreement with Fishers Island Ferry District, to whom federal funds were passed through during the audit period. Specifically, no written agreement was in place outlining the subrecipient’s responsibilities, applicable compliance requirements, or the terms and conditions of the award. Recommendation: We recommend that the Town develop and implement procedures to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds. These agreements should contain all elements required by 2 CFR § 200.332(a), including the identification of the federal award, applicable compliance requirements, and any additional terms and conditions. Corrective Action Plan: In coordination with the Supervisor’s office, Town Attorney’s office, and Comptroller’s office, formal subrecipient agreements will be prepared and executed, with adoption of Town Board resolutions, between the Town of Southold and pass-through entities concurrently as Federal grant contracts are awarded, as applicable. Responsible Individual: Albert J. Krupski Jr., Town Supervisor Paul DeChance, Town Attorney Michelle Nickonovitz, Town Comptroller Planned Date of Implementation: Corrective action plan procedures have already been communicated and implemented to ensure that formal written subrecipient agreements with pass-through entities are executed prior to the disbursement of federal funds.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1162692 2024-001
    Material Weakness Repeat
  • 1162693 2024-001
    Material Weakness Repeat
  • 1162694 2024-001
    Material Weakness Repeat
  • 1162695 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $846,967
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $71,952
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $39,446
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $22,000
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $16,260
16.607 BULLETPROOF VEST PARTNERSHIP PROGRAM $11,980
15.616 CLEAN VESSEL ACT $5,000
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $3,269