Finding 1176619 (2025-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-03-05

AI Summary

  • Core Issue: The Association lacks effective internal controls for monitoring subrecipients, leading to a material weakness in compliance.
  • Impacted Requirements: Failure to meet CFR Part 200 requirements for managing federal awards, specifically regarding subrecipient oversight.
  • Recommended Follow-Up: Implement and document formal policies and procedures for subrecipient monitoring to ensure compliance with federal funding requirements.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Community Project Funding/Congressionally Directed Spending ‐ Construction Assistance Listing Number: 93.493 Federal Award Identification Number and Year: 6-CE1HS52375-07 - 2023 Award Period: September 30, 2023, through September 29, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance – Subrecipient Monitoring • Other Matters Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.303 specifies that a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Evidence of subrecipient monitoring was not available for the five subrecipients selected for testing. Questioned costs: None. Context: Of the five subrecipients selected for testing, we noted that none of them had proper monitoring in place. Cause: The Association did not have internal control systems in place to adequately monitor subrecipients to ensure that the non-federal entity was in compliance with terms of the federal award. Effect: The Association could pass through federal funding to subrecipients who are not responsible or capable recipients of the funds. Funding could be used by the subrecipients in ways that are incompatible with program goals and compliance requirements. Repeat Finding: N/A. Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and approved. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's current monitoring of Subrecipients has included reviewing budgets and progress reports, approving vendors, and processing drawdown requests to confirm the appropriate use of subaward funds in compliance with Federal regulations and subaward terms. However, OARN recognizes the need for a more comprehensive review process to ensure full subrecipient compliance. Therefore, we plan to request audits or financial reviews from all subrecipients. We will also require documentation demonstrating that the subrecipient has taken prompt and necessary corrective action in response to any deficiencies identified through audits, on-site reviews, or other methods related to the Federal program. OARN has created and will maintain a Subrecipient Monitoring and Approval Form that tracks receipt and review of 1) audit reports and corrective actions along with 2) checks on SAM.gov to confirm the subrecipient's continued eligibility for federal funds. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: March 30, 2026

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Other Findings in this Audit

  • 1176620 2025-003
    Material Weakness Repeat
  • 1176621 2025-004
    Material Weakness Repeat
  • 1176622 2025-005
    Material Weakness Repeat
  • 1176623 2025-006
    Material Weakness Repeat
  • 1176624 2025-007
    Material Weakness Repeat
  • 1176625 2025-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.493 Community Project Funding/Congressionally Directed Spending ‐ Construction $2.11M