Finding 1182162 (2025-003)

Finding No. 2025-003: Subrecipient Monitoring AL No.: 11.029 Program Title: Tribal Broadband Connectivity Program Grant Award Number: NT23TBC0290054 Condition Subaward agreements did not include certain required federal award information. A risk assessment was not performed for the subrecipient prior to execution of the subaward agreement. No evidence of pass-through entity verifying that subrecipients are audited as required by 2 CFR Section 200, Subpart F. DHHL failed to communicate five required pieces of award information to the subrecipient (UH) as mandated by 2 CFR 200.332(a)(1), including: Subrecipient’s unique entity identifier, Subaward Budget Period Start and End Date, Assistance Listing Number (12.017), Identification of whether the award is R&D, Indirect cost rate information (including de minimis rate status). Corrective Action Plan DHHL will implement the following corrective actions to address the identified issues to align subrecipient monitoring in compliance with 2 CFR 200. Subaward and Documentation Corrections: DHHL will review the original federal award and UH agreement, then prepare subaward amendments incorporating all required elements under 2 CFR 200.332(a)(1). DHHL will also obtain UH’s UEI and confirm and document the subaward budget period and assistance listing number. DHHL will also assure all amendments and documents obtain NTIA/NIST approval for any required federal documentation. Risk Assessment and Monitoring: DHHL will conduct and document risk assessment for UH in accordance with 2 CFR 200.332(b). DHHL will then use the risk assessment to determine the appropriate level of subrecipient monitoring. Moving forward, DHHL will integrate the risk assessment requirement prior to any subaward execution. Audit Verification and Compliance: DHHL will verify UH’s single audit status, review and document UH’s Single Audit Report to assess and establish annual monitoring/management procedures. DHHL will implement the same processes for future subrecipients moving forward. Systematic Improvements and Training: DHHL will develop a subaward checklist and standardized subaward template aligned with 2 CFR 200.332 requirements. DHHL plans to implement mandatory compliance and legal review prior to subaward execution. Person Responsible Jaren Tengan, Broadband Coordinator And/or Aislen Bacalso, Broadband Coordination Assistant Anticipated Date of Completion The updated documentation is subject to the completion and approval of Federal Budget Amendments. DHHL is hopeful that NTIA and NIST will provide feedback and approval by June 2026, and DHHL will immediately prepare and submit any additional subaward documentation for the UH Subaward. (Please note this is the first fiscal year DHHL is working with NIST. It is unsure how long budget amendment processes will take.)