Finding Text
Condition: During our test of (2) expenditures totaling $332,735, for the Coronavirus State and Local Fiscal Recovery Funds, it was noted the County did not have a subrecipient monitoring policy and did not obtain subrecipient agreements from its two (2) subrecipients comparing the following information: • Subrecipient name. • Subrecipient Authorized Representative and program contact information. • Subrecipient Employee Identification Number (EIN) and Data Universal Numbering System (DUNS) number. • Federal Award Identification Number (FAIN). • Name of Federal Awarding Agency. • Contact information for the official at the Federal Awarding Agency. • Catalog of Assistance Listing (AL) number and name. • Federal award date. • Total amount of the federal award and indirect cost rate. • Federal award project description. • Start and end date of the agreement. • Amount of federal funds budgeted for the agreement and indirect cost rate allowed. • A statement that all activities must be in accordance with federal statutes, regulations, and terms and conditions of the federal award. The subrecipient should receive a copy of the award documents. • A detailed description of any additional requirements you want the subrecipient to be responsible for such as performance and/or financial reports, attending meetings and/or trainings, etc. • A statement about the monitoring activities, such as where/when they will take place; also include a statement indicating the subrecipient will collaborate on monitoring activities including providing requested financial documents. • A statement indicating if any of the items in the agreement change during the period of performance, the agreement will be amended. • Provide close out terms and conditions. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with compliance requirements. Effect of Condition: This condition resulted in noncompliance with grant requirements. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of Federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on Grants and Awards. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. Criteria: 2 CFR 200, §200.332 Requirements for Pass-Through Entities states in part: All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part. (6) Appropriate terms and conditions concerning closeout of the subaward.