Finding Text
Criteria or specific requirement: CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.303 specifies that a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The Organization did not have policies and procedures in place to ensure all the requirements of subrecipient monitoring were being performed. Questioned costs: None. Context: None of the 5 subrecipients selected for testing (out of a population of 10) had proper monitoring in place. Cause: Policies and procedures were not in place to provide adequate subrecipient monitoring. Effect: The Organization could pass through federal funding to subrecipients who are not responsible or capable recipients of the funds. Funding could be used by the subrecipients in ways that are incompatible with program goals and compliance requirements. Repeat finding: Yes. Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Views of responsible officials: There is no disagreement with the audit finding.