Finding Text
Subrecipient Monitoring – Ineligible Subaward (Noncompliance)and Significant Deficiency in Internal Control Finding 2025-003 Identification of the Federal Program: 93.387 – National and State Tobacco Control Program Criteria: According to 2 CFR § 25.300, a recipient may not make a subaward to a subrecipient that has not obtained a UEI and provided it to the recipient. A recipient must notify any potential subrecipients that the recipient cannot make a subaward unless the subrecipient obtains and provides a UEI to the recipient. Condition: For the major program tested, $39,000 of subawards were made to a subrecipient (LIFT), who does not have a UEI. Although due diligence was done in attempted to obtain the information, the EIN was received instead. Cause: Management nor the program manager was unaware of the requirement due to the limited number of subawards that are made outside of the member Tribes, who all have UEI numbers. Effect: The major program is in noncompliance with 2 CFR § 25.300. Questioned Costs: $39,000 Repeat Finding: No Recommendation: We recommend that management reach out to all program managers at the Organization to ensure this information is obtained for all subawards. Additionally, implement the control to verify the information reported on the subaward through the FAC website to ensure it is the correct UEI prior to signing the contract. Management Response: Management agrees with the finding. Communication has been made to program managers regarding the requirement and due diligence will be done in checking the correct UEI with the FAC prior to signing any contracts for subawards.