Finding Text
Finding 2025-003 Subrecipients Information on the Federal Programs: Federal Agency(ies): Department of Health and Human Services Federal Program(s): Strengthening Public Health Systems and Services through National Partnerships to Improve and Protect the Nation’s Health Assistance Listing Number(s): 93.421 Pass-through Entity (if Applicable): None for the awards impacted by the finding.Award Identification Number and Year: 6 NU38PW0000-01-02, 5 NU38PW000033-02-01. Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Recipients that pass Federal funds through to subrecipients must: Make subawards containing all information required by 2 CFR 200.332(a); Evaluate each subrecipient's risk of noncompliance to determine the appropriate level of monitoring under 2 CFR 200.332(b); Distinguish subrecipients from contractors in accordance with 2 CFR 200.331 and apply the appropriate requirements; Maintain adequate policies, procedures, and accounting records to identify and track subaward expenditures separately from contractor expenditures; and Not exceed fixed amount subawards in excess of the limitations established in 2 CFR 200.333. Condition: BCHC had established certain subrecipient oversight practices, including regular meetings with subrecipients and review of invoices prior to reimbursement. However, the Organization's subrecipient monitoring policies, procedures, and documentation did not fully meet the requirements of Uniform Guidance. Specifically: BCHC issued fixed amount subawards that exceeded the maximum amount permitted under 2 CFR 200.333. BCHC did not perform and document risk assessments of subrecipients prior to making awards. Subaward agreements did not include all information required by 2 CFR 200.332(a). BCHC did not consistently distinguish between subrecipients and contractors, as evidenced by the use of contractor procurement documentation (e.g., sole-source justifications) for subrecipient relationships and the commingling of subaward and consulting expenses within the general ledger. While BCHC had established certain monitoring activities, it had not formalized written policies and procedures governing subrecipient determinations and monitoring responsibilities. Cause: BCHC had established certain practices for administering pass-through awards; however, formal written policies and procedures were not in place to comprehensively address subrecipient determinations, risk assessments, subaward issuance, monitoring, and accounting for subrecipient expenditures. In addition, available guidance and controls could be strengthened to better distinguish subrecipients from contractors, ensure all required information is included in subaward agreements, perform and document risk assessments, monitor compliance with fixed-amount subaward limitations, and separately track subaward expenditures. Effect or Potential Effect: These issues increase the risk that Federal funds may not be administered in accordance with Uniform Guidance requirements and that noncompliance by subrecipients may not be identified or addressed in a timely manner. Additionally, BCHC may be unable to demonstrate effective oversight of subawards or provide complete and accurate information regarding subrecipient expenditures.Questioned Costs: Undeterminable. BCHC maintained ongoing communication with and oversight of the subrecipient to monitor progress and completion of the funded activities. In addition, the subrecipient identified and reported the Federal award in its Uniform Guidance audit and no findings related to the award were reported. As a result, while the control deficiencies constitute noncompliance with Uniform Guidance requirements and increase the risk of undetected noncompliance, the auditor was not aware of any specific expenditures that were unallowable, unsupported, or improperly charged to the Federal program. Accordingly, questioned costs, if any, are undeterminable. Context: There was only one subrecipient during 2025 (with 3 separate awards). Identification as a Repeat Finding, if Applicable: This is not a repeat finding. Recommendation: We recommend that BCHC develop, document, and implement formal policies and procedures for the administration and monitoring of subawards in accordance with Uniform Guidance requirements. At a minimum, these procedures should require: (1) a documented assessment of subrecipient risk prior to issuing a subaward and periodic reassessment as appropriate; (2) inclusion of all required Federal award information in subaward agreements; (3) clear criteria and documentation supporting the determination of whether an entity is a subrecipient or contractor; (4) monitoring procedures commensurate with the assessed level of risk; (5) compliance with limitations applicable to fixed amount subawards; and (6) accounting procedures that separately identify and track subrecipient expenditures within the general ledger. In addition, BCHC should provide training to personnel responsible for Federal award administration to ensure Uniform Guidance requirements related to subrecipient monitoring are consistently applied and documented.