Finding 1176644 (2025-010)

Federal Agency: US Department of Agriculture Federal Program Name: Infrastructure Investment and Jobs Act Community Wildfire Defense Grants Cooperative Forestry Assistance Assistance Listing Number: 10.720, 10.664 Federal Award Identification Number, Year and Award Period: ALN 10.720: 23DG11030000019: 7/1/2023 – 12/31/2028 23DG11030000057: 7/1/2023 – 12/31/2026 24DG11030000035: 8/1/2024 – 6/30/2029 ALN 10.664: 20DG11030000007: 7/1/2020 – 12/31/2025 21DG11030000013: 7/1/2021 – 12/31/2025 22DG11030000007: 7/1/2022 – 12/31/2025 23DG11030000008: 7/1/2023 – 12/31/2026 24DG11030000023: 7/1/2024 – 12/31/2027 Type of Finding:  Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: Per 2 CFR §200.332 Requirements for pass-through entities, a non-federal entity must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass_x0002_through entity monitoring of the subrecipient must include reviewing financial and performance reports required by the pass-through entity. Additionally, §200.332 includes required elements that are to be included in the subawards for pass-through entities. Condition: During single audit testwork over subrecipient monitoring, the following issues were noted which are detailed by ALN: ALN 10.720:  5 out of 5 subrecipient samples tested did not have adequate subaward agreements that include the points listed in 2 CFR §200.332 Requirements for pass-through entities.  5 out of 5 subrecipient samples tested listed the incorrect assistance listing number on either the subaward, notice to proceed, or both. ALN 10.664:  9 of 9 subrecipient samples tested did not have adequate subaward agreements that include the points listed in 2 CFR §200.332 Requirements for pass-through entities.  3 of 9 subrecipient samples tested listed the incorrect assistance listing number on either the subaward, notice to proceed, or both.  1 of 9 subrecipient samples were not initially identified as subrecipients for the program due to mapping issues. As result, the Department did not perform any monitoring related to the subrecipient. Questioned costs: None Context: This was identified during Subrecipient Monitoring Testing. The samples described above were statistically valid samples. Cause: The Department has not maintained internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effect: Noncompliance with portions of the applicable regulations. Programmatic monitoring was being performed for the ALNs. Recommendation: We recommend the Department create an agreement template that contains the required elements of a subaward to distribute to its subrecipients. We recommend that the Department conduct training with program staff on required elements of subawards and proper mapping of subrecipients within SHARE.