Finding Text
Statement of Condition For the year ended June 30, 2025, the County did not maintain effective controls over subrecipient monitoring related to Operation Stonegarden. Required subrecipient financial and performance reporting support was not consistently obtained, retained, or reviewed in a timely manner. Specifically: • 24 subrecipient reports and supporting submissions were required under the subaward. • The County was able to provide 7 of the 24 requested reports for audit testing. • Of the 7 reports provided, 3 were received more than 20 days after the required submission date. County personnel indicated that subrecipients did not always submit reimbursement requests and required reports timely; however, the County did not consistently document follow-up actions, escalation, or enforcement of subaward reporting requirements to ensure timely and complete subrecipient reporting. Criteria Title 2 CFR §200.331 requires pass-through entities to monitor subrecipient activities to ensure that subrecipients comply with federal statutes, regulations, and the terms and conditions of subawards, including the timely receipt and review of required financial and performance reports. Cause The County did not design and/or consistently perform a formal subrecipient monitoring process, including (1) a standardized tracking and follow-up protocol for late or missing submissions, (2) evidence of timely review of financial and performance information, and (3) documented escalation and corrective action when subrecipients do not comply. As a result, subrecipient oversight relied largely on voluntary compliance by subrecipients, without sufficient County review, enforcement, or documentation of monitoring activities. Effect Required subrecipient reporting, monitoring, and follow-up were not consistently performed and documented. As a result, the County lacked reasonable assurance that subrecipients complied with subaward terms and that subrecipient expenditures and performance information used for County reporting were allowable, supported, timely, and reliable. Given that subrecipient activity is integral to the administration of the County’s major program, these conditions increase the risk that unsupported or noncompliant subrecipient activity may not be identified and corrected timely. Such conditions may require additional corrective actions or increased scrutiny by grantor or oversight agencies. Recommendation We recommend that the County: • Develop and implement written subrecipient monitoring policies and procedures that clearly define reporting requirements and submission deadlines. • Track subrecipient report due dates and document follow-up efforts for late or missing reports. • Review subrecipient financial and performance reports timely and retain documentation evidencing the review to ensure compliance with grant requirements. Consider withholding reimbursement or implementing other corrective actions when subrecipients fail to submit required documentation timely. • Provide training to staff responsible for subrecipient oversight to strengthen monitoring and compliance. Views of Responsible Officials Management concurs with the finding. The Operation Stonegarden grants are managed by Broken Arrow Services, LLC, who is contracted with Otero County for this purpose. Broken Arrow Services, LLC has communicated to all sub-recipients the importance of submitting reports and invoices in a timely manner so that financial and performance reports can be completed and submitted to DHSEM by the required deadlines each quarter. All late submissions by sub-recipients will be tracked and follow-up efforts will be documented. Reimbursement to sub-recipients who are not in compliance will be withheld until all proper SUBRECIPIENT MONITORING PROCESSES AND CONTROLS Type of Finding: (E) Material Weakness in Internal Control Over Compliance of Federal Awards, (G) Material Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Homeland Security Title: Homeland Security and Emergency Management AL #: 97.067 Award #: EMW-2022-SS-00044 EMW-2023-SS-00015 EMW-2024-SS-05231 Award Period: January 1, 2023-March 31, 2025 Compliance Requirement: Reporting Questioned Costs: None documentation and reporting has been submitted and reviewed for accuracy. Finding Resolutions Timeline: June 30, 2026 Designation Of Employee Position Responsible For Meeting This Deadline: Finance Director