Finding Text
Finding #SA2024-002: Subrecipient Monitoring and Subgrant Reporting on Schedule of Expenditures of Federal Awards Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Pass Through Entity: County of San Mateo Federal Award Identification Number: SFLRP0201 Criteria: 2 C.F.R. Part 200.332 of the Uniform Guidance requires that the City evaluate the risk of noncompliance for its subrecipients and perform monitoring procedures based upon identified risks. Subrecipient monitoring provides reasonable assurance that the subrecipient used the subaward for authorized purposes in compliance with federal statutes, regulations, and the terms and conditions of the subaward. In addition, 2 C.F.R. Part 200.510 (b)(4) of the Uniform Guidance requires that the schedule of expenditures of federal awards include the total amount provided to subrecipients from each Federal program. Condition: The City had identified one subrecipient under the COVID-19 – Coronavirus State and Local Fiscal Recovery Funds grant and we understand the City does not have policies and procedures related to the monitoring of subrecipients. Although City staff did obtain a copy of the subrecipient’s most recent single audit report, we understand that was obtained after we asked about the monitoring procedures. In addition, after the grantor performed the Performance Audit of ARPA Subrecipient Monitoring discussed in finding #SA2024-005, City staff determined that three additional vendors should have been treated as subrecipients, including monitoring the activities and reporting the current year expenditures totaling $367,946 as subgrants in the schedule of expenditures of federal awards. Effect: The City is not in compliance with the subrecipient monitoring and reporting requirements of the Uniform Guidance. Cause: We understand City staff was not aware of the subrecipient monitoring requirements of the Uniform Guidance and had not identified three vendors as subrecipients. Recommendation: The City should develop policies and procedures related to subrecipient monitoring in compliance with the provisions of 2 C.F.R. Part 200.332 and reporting in compliance with the provisions of 2 C.F.R. Part 200.510 (b)(4). View of Responsible Officials and Planned Corrective Actions: Please see Corrective Action Plan separately prepared by the City.