Finding Text
2025-002 Subrecipient Monitoring – Required Award Information Program Information Federal Agency U.S. Department of Health and Human Services, Passed through the Washington State Department of Health Assistance Listing Numbers 93.323 Epidemiology and Laboratory Capacity of Infectious Diseases (ELC) Award Numbers NU50CK000515 Criteria Under 2 CFR 200.332(b), a pass-through entity is required to ensure that every subaward is clearly identified to the subrecipient as a subaward and includes required federal award identification information. Required information includes, among other information, the Federal awarding agency, Federal Award Identification Number (FAIN), and Assistance Listing Number (ALN). [X] Compliance Finding [X ] Significant Deficiency [ ] Material Weakness Condition The Organization was not able to demonstrate that the Federal awarding agency, Federal award identification number (FAIN), and assistance listing number (ALN) were communicated to subrecipients. Cause Required communications were reportedly sent by the former Executive Director via email; however, supporting documentation was not retained or available for audit. Effect Failure to properly identify subawards and communicate required federal award information may result in subrecipients not being fully aware of the federal source of funding, applicable compliance requirements, reporting obligations, indirect cost rate requirements, audit requirements, access-to-records provisions, and closeout responsibilities. This condition increases the risk that subrecipients may not comply with federal statutes, regulations, and award terms and conditions, and that the Organization may not effectively fulfill its pass-through entity responsibilities for subrecipient monitoring. Questioned Costs None noted. Context We selected four subrecipient agreements out of a population of seven. All four agreements tested were missing the required information noted above. Recommendation The Organization should implement procedures to ensure all required subrecipient award information is communicated in accordance with federal requirements as part of the subrecipient agreements. Views of responsible officials and planned corrective action All required funding source information will be included in partner contracts moving forward. Corrective action plan is 2 fold: 1. OCH will email all 2026 subawardees the required funding source information and save this documentation within the appropriate contract folder. 2. OCH will update it’s contract templates to include funding source information and all future contracts will include this within the contract.