Finding 1220136 (2025-002)

2025 – 002 Subrecipient Monitoring – Missing Contract Elements Federal Agency: U.S. Department of Health and Human Services Federal Program Title: HIV Emergency Relief Project Grants HIV Care Formula Grants ALN: 93.914 93.917 Pass-Through Agency: Texas Department of State Health Services Pass-Through Number(s): N/A Award Number and Period: HIV Emergency Relief Project Grants H89HA00014-34, H89HA00014-35 March 1, 2024 – February 28, 2025, March 1, 2025 – February 28, 2026 HIV Care Formula Grants HHS001122200003 April 1, 2022 – March 31, 2026 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2025 – 002 Subrecipient Monitoring – Missing Contract Elements (Continued) Criteria or specific requirement: Per 2 CFR 200.303(a), Dallas County must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that it is managing the Federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Per 2 CFR section 200.332(a), all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the certain required information provided. A pass-through entity must provide the best available information when some of the required information is unavailable. A pass-through entity must provide unavailable information when it is obtained. Required information includes the subrecipient’s unique entity identifier (UEI), federal award identification number (FAIN), federal award date of award to the recipient by the granting agency, and the name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity. Condition: Audit procedures included a review of subaward agreements for required information. We noted the following instances of noncompliance: HIV Emergency Relief Project Grants – The UEI was not included in any of the five subaward agreements selected for testing. The start and end dates for the agreements were March 1, 2024 – February 28, 2025. HIV Care Formula Grants – The UEI, FAIN, federal award date of award to the recipient by the granting agency, and the name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity were not included in any of the five subaward agreements selected for testing. The start and end dates for the agreements were March 1, 2024 – February 28, 2025. Questioned costs: None. Context: See “Condition.” Cause: The current contract review process to ensure all required elements are included per 2 CFR 200 §200.332 prior to execution is not at the correct precision level. Effect: As required subaward information was left out of contracts, Dallas County increased the risk that subrecipients were not fully informed of the federal award details necessary to properly administer the funds in compliance with the applicable statutes, regulations, and award terms. Missing contract elements may impede subrecipients’ ability to accurately identify the federal program, appropriately report activities, and meet federal requirements, including those related to financial management, performance, subrecipient monitoring, and audit preparation. Section III – Findings and Questioned Costs – Major Federal Programs (Continued) 2025 – 002 Subrecipient Monitoring – Missing Contract Elements (Continued) Repeat Finding: No Recommendation: We recommend management enhance existing controls around the review of all subaward agreements to ensure that all pass-through agreements include each of the required elements noted in 2 CFR §200.332. Views of responsible officials: See corrective action plan.