Finding 1239302 (2025-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414150
Organization: Tulsa Community Foundation (OK)
Auditor: HOGANTAYLOR LLP

AI Summary

  • Core Issue: The Foundation failed to perform and document required risk assessments for subrecipients, violating 2 CFR 200.332(c).
  • Impacted Requirements: Lack of formal procedures means monitoring may not effectively address fraud risk and compliance issues, risking noncompliance with federal awards.
  • Recommended Follow-up: Establish and document internal controls for subrecipient monitoring, including a formal risk assessment process to ensure compliance with federal requirements.

Finding Text

Finding: Item 2025-001 – Subrecipient Risk Assessments Not Performed or Documented Significant Deficiency Federal Program – Regional Technology and Innovation Hubs Assistance Listing Number – 11.039 Federal Agency – Economic Development Administration Pass-through Grantor's Numbers – N/A Federal Award Year – December 31, 2025 Criteria: 2 CFR 200.332(c) requires that pass-through entities evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring. This evaluation should be documented and used to support the nature, timing, and extent of subrecipient monitoring procedures performed. Condition/context: The Foundation had not established or documented an ongoing risk assessment process for evaluating the fraud risk and risk of noncompliance for each subrecipient, as required by Uniform Guidance. Although the Foundation performed various subrecipient monitoring activities, it did not document the basis for determining the nature, timing, and extent of those procedures. Cause: The Foundation had not established formal written procedures requiring the completion and documentation of subrecipient risk assessments. Management relied on existing monitoring activities, including the review of subrecipient reports, expenditure documentation, ongoing communication with subrecipients, and knowledge of subrecipient experience with federal awards; however, a formal process had not been implemented to evaluate and document subrecipient risk in accordance with Uniform Guidance requirements. Effect: The lack of documented subrecipient risk assessments could result in monitoring procedures that are not appropriately designed to address each subrecipient's fraud risk and risk of noncompliance with federal award requirements. This could lead to instances of noncompliance, questioned costs, or requests for corrective action by federal agencies. Questioned cost: Not applicable. Repeat finding: No. Recommendation: The Foundation should establish, document, and maintain effective internal control procedures over subrecipient monitoring to provide reasonable assurance that subrecipients are managing federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These procedures should include a documented evaluation of subrecipient risk, as required by 2 CFR 200.332, to support the appropriate level of monitoring performed for each subrecipient. View of responsible officials: Management's response is reported in "Corrective Action Plan" at the end of this report.

Corrective Action Plan

Corrective Action: While program and finance staff historically performed certain informal procedures such as checking for debarment and suspension, verifying SAM status, reviewing available audit reports and related findings, and holding meetings or teleconferences with each subrecipient, these steps were not standardized, consistently applied, or formally documented. The Foundation acknowledges that this lack of a formal, documented risk assessment process does not meet the requirements of 2 CFR 200.332(c). To correct this, the Foundation will establish, document, and maintain effective internal control procedures over annual subrecipient monitoring to provide reasonable assurance that subrecipients are managing federal awards in compliance with 2 CFR 220.332 (c). Risk factors to be evaluated and documented annually will include: • Subrecipient’s prior experience with federal awards; • Results and findings from previous Single Audits and Uniform Guidance monitoring; • Verification of subrecipient's debarment and suspension status, and confirmation of the timely receipt of the subrecipient's annual audited financial statements or Single Audit reporting package, as applicable; • Whether the subrecipient has new personnel working on the grant, including leadership or new or substantially changed systems; • The extent and results of any Federal agency monitoring; • Ongoing programmatic and financial progress monitoring, including tracking of required match/cost-share contributions relative to federal expenditures, with follow-up action when match is not being met proportionally or is trending out of compliance with award terms. The risk assessment will be built into the subaward issuance checklist so no future subawardee agreement is executed without a completed and documented risk assessment on file. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be completed and the process for internal monitoring documentation to be established and shared with all grant subawardees by December 31, 2026 with all annual grant subawardee risk assessments completed no later than January 31st for the previous year during all relevant grant performance periods.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1239297 2025-001
    Material Weakness Repeat
  • 1239298 2025-001
    Material Weakness Repeat
  • 1239299 2025-001
    Material Weakness Repeat
  • 1239300 2025-001
    Material Weakness Repeat
  • 1239301 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $967,335
14.276 YOUTH HOMELESSNESS DEMONSTRATION PROGRAM $529,909
81.086 CONSERVATION RESEARCH AND DEVELOPMENT $50,440
21.009 VOLUNTEER INCOME TAX ASSISTANCE (VITA) MATCHING GRANT PROGRAM $31,441
11.039 REGIONAL TECHNOLOGY AND INNOVATION HUBS $25,675