Finding Text
2022-004 – Subrecipient Monitoring Program: Congressional Appropriations Program (ALN 99.U19) Federal Agency: United States Department of Treasury Criteria: 2 CFR part 200.332 require that all pass-through entities must ensure that every sub-award is clearly identified to the subrecipient as a sub-award and includes the following information at the time of the sub-award and if any of these data elements change, include the changes in subsequent sub-award modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and sub-award. Required information includes (1) Federal Award Identification (i) subrecipient name; (ii) subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date of award to the recipient by the Federal agency (v) sub-award period of performance state and end date; (vi) amount of Federal funds obligated by this action by the pass-through entity to the subrecipient; (vii) total amount of federal funds obligated to the subrecipient by the pass-through entity including the current obligations; (viii) total amount of the federal award committed to the subrecipient by the pass-through entity; (ix) federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (x) name of federal awarding agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xi) ALN number and name; (xii) identification of whether the award is R&D; and (xiii) indirect cost rate for the Federal Award. Condition: The Organization did not include all required information in the subaward agreement per 2 CFR part 200.332. Cause: The Organization does not have effective controls in place to ensure sub-awards contain all required information. Effect: Subgrantees may not have the information needed to identify a subaward as federal funding to ensure compliance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) and specific federal program requirements. Questioned Costs: None Context: The Organization issued 20 subawards during the year. Of the 4 subaward agreements selected for testing through non-statistical sampling, all 4 were missing one or more elements required to be included in subaward agreements under 2 CFR 200.332. Repeat Finding: No Recommendation: We recommend that the Organization review and enhance their current procedures to ensure all requirements found in 2 CFR section 200.332 are present in subaward agreements. Views of Responsible Officials: See Corrective Action Plan.