Finding Text
Finding 2025-001: Subrecipient Monitoring Information on the Federal Programs: Department of Treasury, Assistance Listing Number 21.023 Criteria: Compliance requires a debarment search to be completed for subrecipients and to verify with the subrecipients if they are expected to obtain a financial audit. Condition: Centro Legal de la Raza, Inc. has indicated a debarment search was completed for each subrecipient awarded during the current period, however there was no retention of the search or a review of the search results. In addition, staff did not verify with subrecipients if they were expected to obtain a financial and/or compliance audit. Cause: Centro Legal de la Raza, Inc. staff were not aware that retention of the search or the review of its results was required or that as part of their compliance they should be verifying the subrecipient’s expectation for a financial and/or compliance audit. Context: Without retention, there is no support for the completion of the search or the review of its results. Failure to be aware and following through to obtain (if expected) financial or compliance audits does not allow the Organization to ensure their subawards comply with federal rules. Effect: Centro Legal de la Raza, Inc. may have missed completing a search on a subrecipient or missed reviewing a financial or compliance audit of a subrecipient to ensure compliance of the subaward. Questioned Costs: None noted. Identification as a Repeat Finding: n/a Recommendation: We recommend Centro Legal de la Raza, Inc. staff retain the debarment searches and they develop a procedure in which the searches are reviewed before accepting subrecipients. In addition, Centro Legal de la Raza, Inc. staff should inquire and document of subrecipients their expectation of a financial and/or compliance audit and follow through if one is expected to ensure subawards are complying with federal rules. Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. All relevant staff have also undergone training to ensure compliance at all stages of the debarment process. Name and Title of Responsible Official: Brenda Orellana, Grants Director Planned Completion Date: March 31, 2026.