Finding Text
Item: 2025-002 Assistance Listing Number: 17.280 Program: WIOA Dislocated Worker National Reserve Demonstration Grants Federal Agency: U.S. Department of Labor Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: 23A60YP000003 Award Year: September 30, 2023 to September 30, 2026 Compliance Requirement: Subrecipient Monitoring Criteria: A Pass-Through Entity (PTE) is required to monitor the activities of subrecipients as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: (a) reviewing financial and programmatic (performance and special reports) required by the PTE, (b) following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means, and (c) issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR 200.521. Condition: The Foundation did not complete the required subrecipient monitoring related to review of subrecipient Single Audits and financial statements. Specifically, we noted no evidence that the Foundation verified whether certain subrecipients met the Single Audit threshold under 2 CFR 200.501 or obtained the subrecipients’ Single Audit reporting packages from the Federal Audit Clearinghouse. Additionally, the Foundation did not obtain or document a review of the subrecipients’ audited financial statements (or other financial information) to inform the subrecipient risk assessment under 2 CFR 200.332(b). Questioned Costs: n/a Context: Our testing included the Foundation’s two subrecipients with subawards totaling $225,335 during the audit period. For each subrecipient, we noted that the Foundation did not complete the required subrecipient monitoring related to review of subrecipient Single Audits and financial statements. Specifically, we noted no evidence that the Foundation verified whether certain subrecipients met the Single Audit threshold under 2 CFR 200.501 or obtained their Single Audit reporting packages from the Federal Audit Clearinghouse. Additionally, the Foundation did not obtain or document a review of the subrecipients’ audited financial statements (or other financial information) to inform the subrecipient risk assessment under 2 CFR 200.332(b). Effect: The Foundation is not in compliance with certain subrecipient monitoring requirements. This is deemed to be a material weakness in internal control over compliance. Cause: The Foundation did not have sufficient internal controls over subrecipient monitoring. Specific contributing factors included: (a) lack of formal, documented procedures assigning responsibility for obtaining and reviewing subrecipient single audit reports and/or reviewing financial statements, and (b) lack of formal training on Uniform Guidance subrecipient monitoring requirements. Identification as a Repeat Finding: Not a repeat finding. Recommendation: For the current audit period, we recommend the Foundation obtain missing Single Audit reports and financial statements, complete and document the required reviews, update subrecipient risk ratings, and perform any necessary follow-up or management decisions. Additionally, we recommend the Foundation establish formal written procedures to comply with 2 CFR 200.332(b), (d), and (f), 2 CFR 200.501, and 2 CFR 200.521, including clear steps and timelines for verifying Single Audit applicability, obtaining and reviewing Single Audit reports, and issuing management decisions when applicable. Additionally, for subrecipients not subject to the Single Audit, the Foundation should obtain annual audited financial statements (or other appropriate financial information) and performing a documented financial review to inform the risk assessment. Lastly, the Foundation should provide periodic training to finance and program staff on subrecipient monitoring requirements under the Uniform Guidance. Views of Responsible Officials: Management of the Foundation concurs with the finding. See Corrective Action Plan.