Finding Text
Finding 2024-001: Subrecipient Monitoring Federal Program: Assistance Listing #21.027 - Coronavirus State and Local Recovery Funds. Criteria: A pass-through entity must ensure that every subaward is clearly identified to a subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. (2 CFR 200.332(b)). Condition: Illuminate Colorado has issued subawards to subrecipients to carry out part of its Coronavirus State and Local Recovery Funds program. 2 out of 4 subrecipients were selected for testing. The subawards for these subrecipients were missing the following Federal award identification information: Subrecipient's unique entity identifier. Federal Award Identification Number (FAIN). Federal Award Date. Amount of Federal Funds Obligated in the subaward. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity. Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA). Name of the Federal agency and contact information for the awarding official of the passthrough entity. Item required in accordance with 2 CFR 200.332(b) (formerly 200.331(a)) of the Uniform Guidance. Identification of whether the Federal award is for research and development. Questioned Costs: None. Cause and Effect: Illuminate Colorado has adding provisions in its financial policies and procedures to include the required information in its subawards to subrecipients of Federal funds. While some of the information required by 2 CFR 200.332(b) has been included in the subaward, the information noted above was not. As a result, Illuminate Colorado issued incomplete Federal award information to its subrecipients for this program. This may cause subrecipients to be unable to adhere to any specific compliance requirements, federal laws, regulations, and terms and conditions of the award resulting in noncompliance with all federal rules applicable to the program for which Illuminate Colorado is ultimately responsible. Recommendation: Properly identify subrecipients and ensure subawards include Federal award identification information. Illuminate Colorado can ensure all the required Federal award identification information through a subaward checklist and review by appropriate organization management. Management’s Response: Illuminate Colorado has developed a new process for properly identifying subrecipients and ensuring all required federal award identification information is included in each subaward prior to issuance. This process includes the use of an updated subaward checklist and management review prior to execution of subaward agreements.