Finding 1227177 (2025-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-08-18
Audit: 409338
Organization: Half Moon Bay (CA)

AI Summary

  • Core Issue: The City lacks policies and procedures for monitoring subrecipients, leading to noncompliance with federal requirements.
  • Impacted Requirements: Failure to evaluate risks and monitor subrecipients as mandated by 2 C.F.R. Part 200.332 and to report expenditures as required by 2 C.F.R. Part 200.510 (b)(4).
  • Recommended Follow-Up: Develop and implement comprehensive subrecipient monitoring policies and procedures to ensure compliance with federal guidelines.

Finding Text

Finding #SA2024-002: Subrecipient Monitoring 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 one subrecipient under the COVID-19 – Coronavirus State and Local Fiscal Recovery Fund grant, but we understand the City does not have policies and procedures related to the monitoring of subrecipients. In fiscal year 2025, City staff did not obtain a copy of the subrecipient’s most recent single audit report and did not conduct any other monitoring of the subrecipient. Effect: The City is not in compliance with the subrecipient monitoring and reporting requirements of the Uniform Guidance. Cause: We understand that the City’s program manager in charge of this program has left the City and did not perform monitoring procedures. Identification as a Repeat Finding: Yes, since 2024 (Finding #SA2024-002) 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.

Corrective Action Plan

Finding #SA2025-002: Subrecipient Monitoring 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 • Fiscal Year of Initial Finding: 2024 • Name(s) of the contact person: Kenneth Stiles, Interim Administrative Services Director • Corrective Action Plan: The City will strengthen its subrecipient monitoring practices to comply with 2 C.F.R. § 200.332. Specifically, the City will: 1. Conduct a suspension and debarment check on SAM.gov prior to awarding subrecipient agreements. 2. Update its standard subrecipient agreement template to include a requirement that subrecipients notify the City of any noncompliance or misuse of federal funds. 3. Require subrecipients to submit quarterly programmatic and financial reports to demonstrate proper use of funds and progress toward performance goals. 4. For subrecipients expending $750,000 or more in federal funds, obtain and review their Single Audit reports annually. If below the threshold, request and retain a written statement confirming the subrecipient is not subject to Single Audit requirements. 5. Maintain all documentation related to subrecipient monitoring for a minimum of five years and use a standardized checklist to track compliance. • Anticipated Completion Date: September 2026

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 1227176 2025-001
    Material Weakness Repeat
  • 1227178 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $782,350
20.205 HIGHWAY PLANNING AND CONSTRUCTION $571,753