Finding 1238529 (2025-004)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: The Organization lacks adequate procedures to monitor subrecipients, failing to perform necessary risk assessments and review audit reports.
  • Impacted Requirements: Compliance with 2 CFR Part 200.332 is at risk due to insufficient monitoring and documentation of subrecipient eligibility.
  • Recommended Follow-Up: Establish formal monitoring procedures, including risk assessments and audit reviews, to ensure compliance and mitigate potential issues.

Finding Text

Criteria: In accordance with 2 CFR Part 200.332, pass-through entities are required to evaluate each subrecipient’s fraud risk and risk of noncompliance and determine appropriate monitoring based on that risk. Pass-through entities are also responsible for reviewing applicable audit reports, following up on identified deficiencies or questioned costs, and verifying that subrecipients are eligible to participate in federal programs. Condition: The Organization had not established adequate procedures to monitor 4 of the 9 subrecipients tested receiving federal funds. Documented risk assessments were not performed, applicable audit reports were not consistently obtained and reviewed, and suspension and debarment status was not documented before subawards were issued. Cause: The Organization had not established formal policies governing subrecipient risk assessments, audit report review, suspension and debarment verification, or follow-up procedures. Responsibility for subrecipient monitoring also had not been formally assigned. Effect: The lack of a documented monitoring process increases the risk that noncompliance, audit findings, performance deficiencies, or eligibility issues could occur and remain undetected. Questioned Costs: None noted Repeat Finding: No Recommendation: We recommend that management establish formal subrecipient monitoring procedures that require documented risk assessments, review of applicable audit reports, verification of suspension and debarment status before issuing subawards, and documented follow-up on identified findings. The nature and extent of monitoring should be based on each subrecipient’s assessed risk, with sufficient documentation retained to demonstrate compliance with federal requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding; see corrective action plan.

Corrective Action Plan

All Chicago will: • Develop and implement a standardized pre-award Risk Assessment Questionnaire and scoring matrix. • Develop and implement an official Subrecipient Monitoring Policy that mandates risk scoring before any subaward agreement is fully executed. • Draft and formally adopt procedures requiring a suspension and debarment check via SAM.gov or an alternative verification method for all subrecipients on federal awards. • Obtain, review, and document All Chicago’s internal review of a subrecipient’s single audit report. • Conduct mandatory training sessions for all staff involved in subaward administration regarding this compliance requirement. • Complete a retroactive assessment on active subrecipients.

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1238526 2025-003
    Material Weakness Repeat
  • 1238527 2025-004
    Material Weakness Repeat
  • 1238528 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
14.267 CONTINUUM OF CARE PROGRAM $11.67M
21.023 EMERGENCY RENTAL ASSISTANCE PROGRAM $1.90M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.37M
14.231 EMERGENCY SOLUTIONS GRANT PROGRAM $301,752