Finding Text
Federal Grantor: U.S. Department of Treasury Pass-through Grantor: n/a Assistance Listing No.: 21.027 Program Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Award Year: 2024 Compliance Requirement: Subrecipient Monitoring Known Questioned Costs: n/a Criteria: Part 1 of the Compliance and Reporting Guidance, issued by the U.S. Department of the Treasury, states that "SLFRF recipients that are pass-through entities as described under 2 CFR 200.1 are required to manage and monitor their recipients to ensure compliance with requirements of the SLFRF award pursuant to 2 CFR 200.332 regarding requirements for pass-through entities." Additionally, it is stated that pass-through entities are required to clearly identify to the subrecipient any and all compliance requirements for use of SLFRF funds. Condition: The County requires potential recipients of SLFRF funds to complete an application, which clearly identifies any and all compliance requirements for the use of the SLFRF funds. It also advises potential recipients to retain documentation of all uses of the funds and produce those documents to the County upon request. The County awarded SLFRF funds to two subrecipients. For one of the two subrecipients, the County did not ask the subrecipient to produce any documentation of the use of the funds and, therefore, did not perform their duty as a pass-through entity to manage and monitor their recipients to ensure compliance. Additionally, the County did not properly ascertain that any subrecipients expected to be audited as required by the Uniform Guidance, under subpart F, met this requirement (2 CFR 200.331(f)). This verification performed as part of the required monitoring under 2 CFR 200.331(d)(2) is required to ensure that the subrecipient takes timely and appropriate action on deficiencies detected through audits. Cause: Oversight. Effect: The County, as a pass-through entity, is required to manage and monitor their recipients to ensure compliance with requirements of the SLFRF. By failing to manage and monitor one of their subrecipients, the County is in violation of their responsibility as a pass-through entity. Recommendation: We recommend that the County implement procedures for monitoring the spending of SLFRF funds by subrecipients during, and upon completion of their projects to ensure compliance. Management's Response: The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2026 with reminder notices set in calendar.