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Finding #2024-002 Lack of Subrecipient Monitoring – Rural eConnectivity Pilot Program (ALN 10.752) Federal Agency: U.S. Department of Agriculture Assistance Listing Number (ALN): 10.752 – Rural eConnectivity Pilot Program (Reconnect) Award Year: 2024 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR §200.331 through §200.333, pass-through entities must monitor the activities of subrecipients to ensure that federal awards are used for authorized purposes and in compliance with laws, regulations, and the provisions of contracts or grant agreements. Required monitoring activities include reviewing financial and programmatic reports, following up on deficiencies, and ensuring corrective actions are taken. Condition: The Town passed through approximately $1,650,000 in Rural eConnectivity (ReConnect) funds to a local electric Co-op for broadband infrastructure installation. However, the Town did not perform subrecipient monitoring by identifying applicable requirements for the award during or after the disbursement of these funds. The requirements imposed by the Town to the Co-op so the federal award was in accordance with federal statutes, regulations, and terms and conditions as well as any additional requirements in order for the Town to meet its own responsibilities for the federal award were not clearly communicated or imposed. Cause: Town officials stated that they believed subrecipient monitoring was not necessary because the funds had already been expended and the project was completed. Additionally, there was limited communication between the Town and the federal awarding agency, which contributed to a misunderstanding of the Town’s responsibilities as a pass-through entity. Effect: The lack of subrecipient monitoring represents noncompliance with federal requirements and creates a risk that funds may not have been used for their intended purpose. Without adequate oversight, the Town cannot demonstrate that the subrecipient complied with the terms and conditions of the federal award. Questioned Costs: None. Recommendation: We recommend that the Town establish and implement a formal subrecipient monitoring process for all federal funds passed through to other entities. This should include risk assessments, written agreements with compliance terms, ongoing monitoring (e.g., review of performance and financial reports), and follow-up procedures. The Town should also seek guidance from the awarding agency if responsibilities are unclear. Views of Responsible Officials: The Town concurs that applicable requirements for the award were not identified for the subrecipient, however the Town did monitor activities of the subrecipient. The Town monitored activities to ensure funds were used for allowable activities.