Finding Text
2023-004 Subaward Monitoring Federal Program: Research and Development Cluster (ALN 47.041-Engineering, Award 1940055, Award Period 9/1/19 – 3/31/25) Federal Agency: National Science Foundation Criteria: Written documentation pertaining to the identification, risk assessment of and monitoring of sub awardees was not available as required by 2 CFR 200.331-333. Condition: While no funds were passed through to subrecipients during the year, the Organization still lacked documentation to indicate compliance with subaward monitoring responsibilities required Per 2 CFR 200.331-333, including the policies and procedures to identify and assess risks and monitor subaward recipients as required by grant recipients. Cause: The Organization lacked written policies and procedures to execute appropriate subaward monitoring responsibilities. Effect: The organization is not compliant with 2 CFR 200.331-333 which requires the Organization to monitor that the sub awardee is maintaining adequate financial reporting, recordkeeping and compliance with respect to funds received. The Organization could not document sub-awardee risk assessment or monitoring or reviewed debarment or suspension of the sub-awardee. Without policies to document, monitor and risk assess a sub awardee, the Organization could inadvertently engage in a relationship with a sub awardee of higher risk without the appropriate level of oversight to ensure the sub awardee is expending the funds in accordance with the provisions and terms of the subaward. Identification as a repeat finding, if applicable: The finding is a repeat of Finding 2022-006 in the prior year. Recommendation: We recommend the Organization establish policy and procedures to document how sub awardees are selected, monitored and perform required risk assessment pertaining to the selection of the sub awardee. View of Responsible Officials: The Organization has since established appropriate procedures for sub awardee monitoring. Questioned Costs: None