Finding 1210880 (2025-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-04-30

AI Summary

  • Core Issue: ASTHO failed to ask subrecipients about their Single Audits and did not obtain necessary audit copies, leading to noncompliance with federal monitoring requirements.
  • Impacted Requirements: This finding relates to Sections 200.332(c) and 200.332(e)(2) of the Uniform Guidance, which mandate risk assessments and corrective actions for subrecipients.
  • Recommended Follow-Up: ASTHO should establish a procedure to consistently obtain and review Single Audit information from subrecipients annually.

Finding Text

Finding 2025-002 Subrecipient Monitoring Finding Type Other matters compliance finding and significant deficiency in internal control over compliance. Agency U.S. Department of Health and Human Services Assistance Listing Numbers 93.421, Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health 93.078, Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Criteria Section 200.332(c) of the Uniform Guidance requires recipients of federal awards to evaluate each subrecipient’s risk of noncompliance for the purpose of determining the appropriate subrecipient monitoring related to the subaward. One of the risk assessment procedures includes considering whether or not a subrecipient receives a Single audit and the extent to which the same or similar subawards have been audited as a major program. In addition, Section 200.332(e)(2) of the Uniform Guidance requires pass-through entities to ensure that subrecipients take corrective action on all significant developments that negatively affect the subaward, including Single Audit findings related to the subaward. Condition and Context During our audit procedures, we selected four subrecipients for subrecipient monitoring procedures testing. We noted that during the year ended September 30, 2025, ASTHO had not asked these subrecipients if they had Single Audits. Likewise, during the year ended September 30, 2025, ASTHO had not obtained copies of the subrecipients’ most recent Single Audits. However, ASTHO performed other subrecipient monitoring procedures such as checking for debarment, reviewing documentation for reimbursement requests, and obtaining progress reports from the subrecipients. Cause ASTHO did not complete its procedures to annually obtain and review the required information related to its subrecipients’ Single Audits. Effect ASTHO was not in compliance with the subrecipient monitoring requirements of the Uniform Guidance. However, the other subrecipient monitoring procedures performed by ASTHO served to mitigate the risk of a material noncompliance related to the major programs. Repeat Finding No. Recommendation We recommend that ASTHO implement a procedure to allow for the consistent ability to obtain and review the required Single Audit information from its subrecipients on an annual basis. Views of Responsible Officials and Planned Corrective Action See attached corrective action plan. Questioned Costs None.

Corrective Action Plan

ASTHO concurs with this recommendation. The CFO/Vice President, Finance will: 1. Update subrecipient monitoring procedures to determine at time of subaward: a. If subrecipient has a history with ASTHO b. If subrecipient is required to conduct a single audit c. Obtain copies of single audits for the applicable period. 2. Require no later than September 15, 2026, Program Operations will ensure for all subrecipients included on preliminary SEFA as of July 31, 2026, that any single audit reports have been collected and reviewed. 3 Require that upon completion of the final SEFA for the year ended September 30, 2026, single audits have been obtained and reviewed for any subrecipients that were not reported on the preliminary July 31, 2026 SEFA. 4. These processes will be repeated for years subsequent to 2026.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1210877 2025-001
    Material Weakness Repeat
  • 1210878 2025-001
    Material Weakness Repeat
  • 1210879 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $32.26M
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $25.28M
93.078 STRENGTHENING EMERGENCY CARE DELIVERY IN THE UNITED STATES HEALTHCARE SYSTEM THROUGH HEALTH INFORMATION AND PROMOTION $2.88M
93.011 NATIONAL ORGANIZATIONS FOR STATE AND LOCAL OFFICIALS $995,992
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $444,572
93.322 CDC PARTNERSHIP: STRENGTHENING PUBLIC HEALTH LABORATORIES $406,596
93.185 IMMUNIZATION RESEARCH, DEMONSTRATION, PUBLIC INFORMATION AND EDUCATION TRAINING AND CLINICAL SKILLS IMPROVEMENT PROJECTS $347,567
93.103 FOOD AND DRUG ADMINISTRATION RESEARCH $334,966
66.510 SURVEYS, STUDIES, INVESTIGATIONS AND SPECIAL PURPOSE GRANTS WITHIN THE OFFICE OF RESEARCH AND DEVELOPMENT $152,841
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $105,068
93.334 THE HEALTHY BRAIN INITIATIVE: TECHNICAL ASSISTANCE TO IMPLEMENT PUBLIC HEALTH ACTIONS RELATED TO COGNITIVE HEALTH, COGNITIVE IMPAIRMENT, AND CAREGIVING AT THE STATE AND LOCAL LEVELS $60,871
93.318 PROTECTING AND IMPROVING HEALTH GLOBALLY: BUILDING AND STRENGTHENING PUBLIC HEALTH IMPACT, SYSTEMS, CAPACITY AND SECURITY $50,471
14.913 HEALTHY HOMES PRODUCTION PROGRAM $36,219
11.431 CLIMATE AND ATMOSPHERIC RESEARCH $22,900