Finding 1237675 (2025-001)

Criteria or Specific Requirement Per 2 CFR § 200.332(b)(1) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the available information when it is obtained. Required information includes: (1) Federal award identification. (i) Subrecipient's name (must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated in the subaward; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; (xii) Assistance Listings title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at the time of disbursement; (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) In addition, direct recipients passing funds to subrecipients are required to have subrecipient monitoring controls in accordance with CFR § 200-331. Under this CFR, internal controls should designed and operating effectively to provide reasonable assurance that the subrecipient used the subaward for authorized purposes in compliance with statutes, regulations, and terms and conditions of the subaward; referred to as subrecipient monitoring. Condition The County did not have an adequate process, or internal controls designed to ensure compliance with subaward agreements and monitoring procedures. Questioned Costs None. Context The County passed funding to one subrecipient and one subrecipient was selected for testing in fiscal year 2025. Based upon the subrecipient selected for testing, the subrecipient agreement was executed but did not include all required information under CFR § 200.332. In addition, the County does not have a formal process to monitor expenditures incurred by subrecipients. Reimbursement requests are submitted by subrecipients but supporting documentation was not consistently provided by subrecipient to enable the County to effectively monitor subrecipient expenditures. Cause The County’s subrecipient contracting process is not designed to include all information required under CFR § 200.332. The County has not implemented internal controls and formal policies and procedures over subrecipient monitoring. Effect Federal Funding lacking proper monitoring procedures could cause subrecipients to spend money on unallowable activities. Grant awards not containing required information won't allow subrecipients to be fully aware of grant requirements. Recommendation We recommend the County design subrecipient contracting internal controls to include all necessary information under CFR § 200.332. We recommend implementing an official policy and design internal controls that outlines monitoring procedures and documentation of these procedures when funding is passed through to subrecipients. Repeat Finding Yes, prior year finding 2024-002 Views of Responsible Officials There is no disagreement with the audit finding.