Finding Text
Significant deficiency in internal control over compliance related to subrecipient monitoring Federal Agency: Department of Health and Human Services Program Title: Social Services Research and Demonstration Program Assistance Listing Number: 93.647 Project Number: 90XP0459-01-00 Award Period: August 31, 2022 – August 30, 2023 Criteria Title 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), specifically 2 CFR 200.332, requires pass-through entities to clearly identify every subaward as a subaward and include specific information in the subrecipient agreement at the time of the subaward. This includes the Assistance Listing number (formerly CFDA number) and the federal award name (title), as well as other key elements. If this information is not available at the time of the subaward, the pass-through entity must provide the best information available and update the subrecipient when the correct information becomes available. These requirements are intended to ensure subrecipients can properly identify the federal program and comply with all applicable requirements under the award, including compliance with federal statutes, regulations, and the terms and conditions of the agreement, as well as the evaluation of each subrecipient’s risk of noncompliance and review of the results of a subrecipient’s annual Single Audit, if required. Condition The Organization’s subaward agreements do not clearly identify all Federal award information and other terms as required—such as the Assistance Listing number, federal award name, and other key elements—in subrecipient agreements at the time of the subaward. Cause The Organization’s subrecipient monitoring policies and procedures were not sufficient to ensure all required subaward terms were included. Effect or Potential Effect For the two subrecipient selected for testing, the Organization’s subaward agreements do not have the correct documentation required to be in compliance with 2 CFR 200.332. Questioned Costs Not applicable. Recommendation We recommend that management develop and formalize procedures to ensure all subawards are clearly identified and that all required information is included in subrecipient agreements at the time of the award. Views of Responsible Officials Management concurs with the finding and has provided the accompanying management corrective action plan.