Finding Text
Criteria Under 2 CFR 200.332(b), pass-through entities must provide specific information to subrecipients at the time of subaward, including at minimum the Assistance Listing number and title, Federal Award Identification, Subaward Period of Performance, Total amount of Federal funds, name of Federal agency, indirect cost rate, and all applicable Federal statutes, regulations, and the terms and conditions of the Federal award, among other elements. Condition The auditee, acting as a pass-through entity, did not inform subrecipients of the required information at the time of subaward. Cause The entity did not have sufficient controls in place to ensure that all required information under Uniform Guidance were communicated to subrecipients at the time of the award. Effect Subrecipients may be unaware of key Federal requirements, which can increase the risk of noncompliance with allowable costs, reporting, and audit requirements. Questioned Costs No questioned costs. Recommendation We recommend the entity implement a process to perform subrecipient vs. contractor determinations for organizations it engages with using federal funding, and ensure the appropriate language required by Uniform Guidance is included in the agreement. Context/Sampling During the audit, we examined agreements with two other entities that the auditee contracted with to perform program activities.