Finding Text
Department of Education, passed through the North Dakota Department of Public Instruction ALN 84.371C, award numbers S371C190005 and S371C190005-22DD, Comprehensive Literacy State Development. Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria - Requirements contained in 2 CFR Part 200.331 specifies that pass-through entities be responsible for identifying Federal Award information and applicable compliance requirements at the time of awards to subrecipients; for monitoring the subrecipient's use for Federal awards; providing reasonable assurance that the subrecipient administers Federal awards in compliance with laws, regulations, and the provisions of contracts or grant agreements; ensuring that subrecipients have required audits completed, reviewing the results of those audits; and evaluating the impact of subrecipient activities on the pass-through entity's ability to comply with applicable Federal regulations. Condition - There were no formal agreements between the District and its subrecipients as required in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Cause - The District's agreements with subrecipients must properly follow Uniform Guidance and no formal monitoring procedures were in place. Effect - Lacking controls could lead to noncompliance with the requirements of the program by subrecipients and could require the return of grant funds to the grantor agency or the entity receiving less grant funds than they were eligible for. Questioned Costs - None reported Context/Sampling - 100% of the subrecipient entities were selected for subrecipient monitoring testing. Repeat Finding from Prior Year - No Recommendation - We recommend the District maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring processes over subrecipient entities. Views of Responsible Officials - There is no disagreement with the audit finding.