Finding 1225290 (2024-005)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2026-07-31

AI Summary

  • Core Issue: ICFJ did not conduct a required pre-award risk assessment for a subrecipient, which is essential for compliance monitoring.
  • Impacted Requirements: Compliance with 2 CFR Part 200.332, which mandates evaluation of subrecipient risks and monitoring of financial and performance reports.
  • Recommended Follow-Up: ICFJ should update sub-recipient policies to ensure risk assessments are completed before engagement, and maintain thorough documentation of all reporting and reviews.

Finding Text

Finding 2024-005 Subaward Monitoring Federal Agencies: U.S. Department of State Federal Programs: International Programs to Support Democracy, Human Rights, and Labor Assistance Listing Numbers: 19.345 Pass-through Entity: None Award Identification Number and Year: S-LMAQM-20-GR-2099, S-LMAQM-20-GR-2100, SAQMIP- 22-GR-0005, S-AQMIP-23-GR-0343 Criteria or Specific Requirement: As noted in 2 CFR Part 200.332 all pass-through entities must evaluate each subrecipient’s risk of noncompliance. Pass-through entity monitoring must include reviewing financial and performance reports required by the pass-through entity, and following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Condition: ICFJ was unable to provide documentation that a pre-award risk assessment had occurred for a subrecipient sampled during the audit. Cause: ICFJ experienced transition during the fiscal year and certain documents were unable to be located during the audit process. Effect or Potential Effect: Subrecipient monitoring is important to ensure proper stewardship and use of Federal funding. Questioned Costs: None Context: The program only included one significant subrecipient. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that ICFJ revisit their sub-recipient policies and ensure that all risk assessments are complete and approved prior to working with a subrecipient, all reporting includes indication of person submitting, date submitted, as well as person reviewing and approving and date. RCA audits, when applicable, should be obtained and reviewed annually. Documentation of this review (or documentation that the requirement does not apply) should be maintained as well.

Corrective Action Plan

Views of Responsible Officials: Management acknowledges the condition noted regarding the pre-award risk assessment. ICFJ is committed to ensuring that all subrecipient monitoring procedures are followed consistently and documented completely. Going forward, a pre-award risk assessment will be completed and approved for all subrecipients prior to execution of any subaward agreement. ICFJ will also ensure that all subrecipient reporting includes the name and date of the submitter and reviewer, and that applicable RCA audits are obtained and reviewed annually with documentation of that review maintained on file.  Anticipated completion date: 9/30/26  Responsible position: Chief Financial Officer

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1225275 2024-001
    Material Weakness Repeat
  • 1225276 2024-003
    Material Weakness Repeat
  • 1225277 2024-004
    Material Weakness Repeat
  • 1225278 2024-005
    Material Weakness Repeat
  • 1225279 2024-001
    Material Weakness Repeat
  • 1225280 2024-003
    Material Weakness Repeat
  • 1225281 2024-004
    Material Weakness Repeat
  • 1225282 2024-005
    Material Weakness Repeat
  • 1225283 2024-001
    Material Weakness Repeat
  • 1225284 2024-003
    Material Weakness Repeat
  • 1225285 2024-004
    Material Weakness Repeat
  • 1225286 2024-005
    Material Weakness Repeat
  • 1225287 2024-001
    Material Weakness Repeat
  • 1225288 2024-003
    Material Weakness Repeat
  • 1225289 2024-004
    Material Weakness Repeat
  • 1225291 2024-001
    Material Weakness Repeat
  • 1225292 2024-002
    Material Weakness Repeat
  • 1225293 2024-003
    Material Weakness Repeat
  • 1225294 2024-004
    Material Weakness Repeat
  • 1225295 2024-001
    Material Weakness Repeat
  • 1225296 2024-002
    Material Weakness Repeat
  • 1225297 2024-003
    Material Weakness Repeat
  • 1225298 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $496,531
19.221 REGIONAL DEMOCRACY PROGRAM $302,000
19.900 AEECA/ESF PD PROGRAMS $212,749
19.345 INTERNATIONAL PROGRAMS TO SUPPORT DEMOCRACY, HUMAN RIGHTS AND LABOR $143,345
19.415 PROFESSIONAL AND CULTURAL EXCHANGE PROGRAMS - CITIZEN EXCHANGES $113,853
19.021 INVESTING IN PEOPLE IN THE MIDDLE EAST AND NORTH AFRICA $97,032
19.022 EDUCATIONAL AND CULTURAL EXCHANGE PROGRAMS APPROPRIATION OVERSEAS GRANTS $48,765
19.750 BUREAU OF WESTERN HEMISPHERE AFFAIRS ASSISTANCE COORDINATION (WHA/AC) GRANT PROGRAMS $39,764
19.040 PUBLIC DIPLOMACY PROGRAMS $19,514
19.108 BUREAU OF SOUTH AND CENTRAL ASIAN AFFAIRS $7,713
19.989 STATE/AFRICAN REGIONAL - OTHER ECONOMIC SUPPORT FUNDS (ESF) PROJECTS/PROGRAMS $6,054
19.501 PUBLIC DIPLOMACY PROGRAMS FOR AFGHANISTAN AND PAKISTAN $3,690
19.979 REGIONAL PEACE AND SECURITY $711