Finding 12153 (2022-001)

-
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2022-12-21

AI Summary

  • Core Issue: The District failed to assess the risk of noncompliance for all subrecipients in fiscal year 2022.
  • Impacted Requirements: This oversight violates 2 CFR section 200.332, which mandates risk evaluations for subrecipient monitoring.
  • Recommended Follow-up: The District should conduct and document a comprehensive risk assessment for all subrecipients receiving federal funding.

Finding Text

Reference Number: 2022-001 Assistance Listing Number: 84.425 Federal Program Title: Education Stabilization Fund Awarding Agency / Pass-Through Entity: U.S. Department of Education, Colorado Department of Education Compliance Requirement: Subrecipient Monitoring Criteria: Under 2 CFR section 200.332, Requirements for Pass-through Entities, all pass-through entities must: (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in section 200.501.?Condition: During procedures performed over the subrecipient monitoring compliance requirements, we noted that the District did not conduct an assessment/evaluation over the risk of noncompliance of all subrecipients in fiscal year 2022. Cause: The condition appears to be caused by an oversight by the District. Questioned Costs: None Recommendation: We recommend the District perform and document a risk assessment/evaluation of noncompliance on all subrecipents receiving federal funding. Views of Responsible Officials: The District agrees with the auditing finding. See separately prepared Corrective Action Letter.

Corrective Action Plan

Reference Number: 2022-001 Assistance Listing Number: 84.425 Federal Program Title: Education Stabilization Fund Awarding Agency / Pass-Through Entity: U.S. Department of Education, Colorado Department of Education Compliance Requirement: Subrecipient Monitoring Criteria: None for ECSD Corrective Action: The District agrees with the finding and has adopted Policy Regulations: DD-R, Project Partnerships, Sub-Award Grants, Sub-Contracts Pursuant to Grants, and Third-Party Grants Involving District Personnel, Programs or Facilities and; DD-R2, Grants to District Personnel Personnel Responsible: Sandra Farrell, COO and Chelsey Gerard, Director of Finance Completion Date: October 31, 2022

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
10.665 Schools and Roads - Grants to States $594,575
84.010 Title I Grants to Local Educational Agencies $556,105
10.553 School Breakfast Program $340,897
84.365 English Language Acquisition State Grants $154,992
84.027 Special Education_grants to States $145,724
84.367 Improving Teacher Quality State Grants $122,432
10.555 National School Lunch Program $98,677
84.048 Career and Technical Education -- Basic Grants to States $63,827
10.559 Summer Food Service Program for Children $48,367
93.600 Head Start $47,462
84.424 Student Support and Academic Enrichment Program $37,271
84.173 Special Education_preschool Grants $34,805
84.425 Education Stabilization Fund $12,203
45.310 Grants to States $7,000
10.649 Pandemic Ebt Administrative Costs $3,063