Finding Text
Awards to Subrecipients Criteria – The Uniform Guidance, Part 200.332 states, “All pass-through entities must: ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of those data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.” Required information includes, in part, identification of whether the award is research and development (R&D), the indirect cost rate for the federal award (including if the de minimis rate is charged) per Part 200.414, the subrecipient unique identifier (UEI #), the federal award date of award to the recipient by the Federal agency, the Assistance Listing number and Title. Additionally, the Workforce Innovation and Opportunity Act (WIOA) Section 102(b) defines priority of service for veterans and eligible spouses and WIOA Section 502(a) states that no WIOA funds can be spent unless the subrecipient agrees to comply with the Buy American Act. Condition – For subawards the Local Workforce Development Area did not include identification of whether the award is R&D, the indirect cost rate for the federal award (including if the de minimis rate is charged) per part 200.414, the subrecipient UEI, the federal award date of award to the recipient by the Federal agency, the Assistance Listing number and Title. Additionally, the Final Decision letter and Initial monitoring report were not signed. Cause – The Local Workforce Development Area has not established policies and procedures to ensure all required information is included in the subaward to the subrecipients. Effect – The information required in the subaward to subrecipients was not included due to the lack of policies and procedures. Recommendation – The Local Workforce Development Area should establish policies and procedures to ensure all required information is included in the subaward to subrecipients as required by Uniform Guidance, Part 200.332 and WIOA. Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provided to Iowa Workforce Development (IWD) and AOS Senior Auditor Tristan Swiggum. Conclusion – Response accepted.