Finding Text
Significant deficiency in internal control over compliance related to subrecipient monitoring. Federal Agency: U.S. Department of Commerce ‐ The National Telecommunications and Information Administration Program Title: Public Wireless Supply Chain Innovation Fund Grant Program Assistance Listing Number: 11.038 Project Number: 06-60-IF008 Award Period: December 1, 2023 - November 30, 2025 Criteria Requirements contained in Title 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D require a pass-through entity to establish compliance policies to ensure subrecipients comply with requirements under the award including the evaluation of each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of such agreements, as well as, reviewing the results of a subrecipient’s annual Single Audit if one is required. Cause Open Networking Organization does not have a formal subrecipient monitoring policy, including requirements for the retention of a documented subrecipient risk assessment and documented review of subrecipient Single Audit reports. Effect or Potential Effect For the one subrecipient selected for testing, the Organization could not produce documentation of the required subrecipient risk assessment nor documented review of the subrecipient’s Single Audit report. Questioned Costs Not applicable. Repeat Finding No Recommendation We recommend that management develop and formalize a subrecipient monitoring policy in accordance with 2 CFR Part 200, including use of a documented subrecipient risk assessment and documented review of subrecipient Single Audit reports. Views of Responsible Officials Management concurs with the finding and has provided the accompanying management corrective action plan.