Finding 1218014 (2024-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2026-06-20
Audit: 404207
Organization: Papa Ola Lokahi (HI)
Auditor: KKDLY LLC

AI Summary

  • Core Issue: The Organization failed to determine whether parties receiving Federal funds were subrecipients or contractors, violating Uniform Guidance requirements.
  • Impacted Requirements: Noncompliance with subrecipient monitoring and management policies as outlined in 2 CFR §200.331 and 2 CFR §200.332.
  • Recommended Follow-Up: Update policies and procedures to include subrecipient monitoring provisions to ensure compliance with Federal standards.

Finding Text

Material Weakness Finding No. 2024-002: Subrecipient Monitoring U.S. Department of Health and Human Services Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. U.S. Department of Health and Human Services Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. Criteria Pursuant to Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), “a non-Federal entity may concurrently receive Federal awards as a recipient, subrecipient, and a contractor, depending on the substance of its agreements with the Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor.” Condition We noted that the Organization did not make case-by-case determinations of each agreement with parties to which the Organization passed through Federal program funds to determine whether they were deemed to be either subrecipients or contractors. Cause Management had not updated its policies and procedures to incorporate the relevant Uniform Guidance subrecipient monitoring and management policies. Effect The lack of subrecipient monitoring and management policies of the Uniform Guidance could result in noncompliance by the Organization with the stipulated requirements for pass-through entities, as well as noncompliance of subrecipient requirements by the entities receiving the pass-through funds from the Organization. Identification of Repeat Finding This finding was reported as a federal award finding in the immediate previous audit as Finding No. 2023-002. Recommendation We recommend that the Organization incorporate and adhere to the subrecipient monitoring and management provisions of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance to their policies and procedures manual to ensure compliance with Federal standards.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action While the Organization concurred with the prior year (2023-002) and current year renumbered recommendation (2024-002), the Organization notes the corrective actions that have been implemented, specifically, related to the subrecipient monitoring and management provision of 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, that emphasizes accountability and compliance in managing federal funds and subrecipients, and that have been in practice, from the effective date(s) noted below, to the present period of the report dated June 17, 2026: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). The Organization performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. By December 31, 2024, the Organization updated and implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc.; and the current practices of the Organization to the present period of the report dated June 17, 2026, is consistent with such developed subrecipient policies and procedures.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1218007 2024-002
    Material Weakness Repeat
  • 1218008 2024-002
    Material Weakness Repeat
  • 1218009 2024-002
    Material Weakness Repeat
  • 1218010 2024-002
    Material Weakness Repeat
  • 1218011 2024-002
    Material Weakness Repeat
  • 1218012 2024-002
    Material Weakness Repeat
  • 1218013 2024-002
    Material Weakness Repeat
  • 1218015 2024-003
    Material Weakness Repeat
  • 1218016 2024-003
    Material Weakness Repeat
  • 1218017 2024-003
    Material Weakness Repeat
  • 1218018 2024-003
    Material Weakness Repeat
  • 1218019 2024-003
    Material Weakness Repeat
  • 1218020 2024-003
    Material Weakness Repeat
  • 1218021 2024-003
    Material Weakness Repeat
  • 1218022 2024-003
    Material Weakness Repeat
  • 1218023 2024-004
    Material Weakness Repeat
  • 1218024 2024-004
    Material Weakness Repeat
  • 1218025 2024-004
    Material Weakness Repeat
  • 1218026 2024-004
    Material Weakness Repeat
  • 1218027 2024-004
    Material Weakness Repeat
  • 1218028 2024-004
    Material Weakness Repeat
  • 1218029 2024-004
    Material Weakness Repeat
  • 1218030 2024-004
    Material Weakness Repeat
  • 1218031 2024-005
    Material Weakness Repeat
  • 1218032 2024-005
    Material Weakness Repeat
  • 1218033 2024-005
    Material Weakness Repeat
  • 1218034 2024-005
    Material Weakness Repeat
  • 1218035 2024-005
    Material Weakness Repeat
  • 1218036 2024-005
    Material Weakness Repeat
  • 1218037 2024-005
    Material Weakness Repeat
  • 1218038 2024-005
    Material Weakness Repeat
  • 1218039 2024-006
    Material Weakness Repeat
  • 1218040 2024-006
    Material Weakness Repeat
  • 1218041 2024-006
    Material Weakness Repeat
  • 1218042 2024-006
    Material Weakness Repeat
  • 1218043 2024-006
    Material Weakness Repeat
  • 1218044 2024-006
    Material Weakness Repeat
  • 1218045 2024-006
    Material Weakness Repeat
  • 1218046 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $1.24M
84.362 NATIVE HAWAIIAN EDUCATION $710,867
93.932 NATIVE HAWAIIAN HEALTH CARE SYSTEMS $281,520
93.387 NATIONAL AND STATE TOBACCO CONTROL PROGRAM $94,587
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $59,054
93.837 CARDIOVASCULAR DISEASES RESEARCH $21,218
93.110 SPECIAL PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $20,590
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $18,362
93.185 IMMUNIZATION RESEARCH, DEMONSTRATION, PUBLIC INFORMATION AND EDUCATION TRAINING AND CLINICAL SKILLS IMPROVEMENT PROJECTS $15,770