Finding 1236563 (2025-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-09-25

AI Summary

  • Core Issue: The Board failed to adequately monitor the subrecipient, Behavioral Health Partners, for compliance with federal grant requirements.
  • Impacted Requirements: This oversight violates 45 C.F.R. § 75.352, which mandates monitoring to ensure funds are used appropriately.
  • Recommended Follow-Up: The Board should review and enhance its monitoring procedures, notify subrecipients of their obligations, and implement regular checks to ensure compliance.

Finding Text

45 C.F.R. § 75.352(a) and (d) requires that all pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. The Board entered into an agreement with Behavioral Health Partners of Central Ohio, Inc. and passed through $2,700,000 of federal Coronavirus State and Local Fiscal Recovery Funds to them. The Board did not properly monitor the activity of the subrecipient related to the grant requirements. Without adequate procedures in place to monitor subrecipient compliance with federal statutes, laws and regulations, there is an increased risk subrecipients may misuse subaward funds for unauthorized purposes. This could lead to fines, penalties, or repayment of program funding being imposed by the federal grantor agency. The Board should evaluate its current control procedures and processes over subrecipient monitoring and update them as necessary to reasonably ensure compliance with 45 C.F.R. § 75.352. The Board should ensure that subrecipients are properly notified of the subaward along with the requirements imposed by the pass through-entity on the subrecipient. The Board should also perform monitoring procedures over the subrecipient activity to ensure that the grant requirements are met.

Corrective Action Plan

Use of subrecipient determination form and implementation of subrecipient monitoring form.

Categories

Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $2.70M
93.788 OPIOID STR $1.07M
93.912 RURAL HEALTHCARE SERVICES PROGRAMS $247,525
93.667 SOCIAL SERVICES BLOCK GRANT $112,069
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $91,060
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $48,614
14.218 COMMUNITY DEVELOPMENT BLOCK GRANTS/ENTITLEMENT GRANTS $42,165