Finding 1239317 (2025-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414163
Organization: Bassett Healthcare Network (NY)
Auditor: KPMG

AI Summary

  • Core Issue: Bassett Health Network failed to adequately monitor subrecipients, lacking necessary documentation for fraud risk evaluations and compliance checks.
  • Impacted Requirements: Noncompliance with 2 CFR 200.332 regarding subrecipient monitoring and risk assessment procedures.
  • Recommended Follow-Up: Develop and implement written policies to ensure consistent documentation and execution of required monitoring activities for subrecipients.

Finding Text

Findings and Questioned Costs Relating to Federal Awards Finding Reference Number: 2025-001 Bassett Health Network Research and Development Cluster (93.262) Federal Award Number: U54OH007542, 23U01OH012656, R01OH011668, U13OH01282 Federal Award Year: 2025 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness and Material Noncompliance Prior Year Finding: N/A Statistically Valid Sample: No Criteria Title 2 of the Code of Federal Regulations, Part 200 — Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR 200) section 200.332(c) states a passthrough entity should evaluate each subrecipient's fraud risk and risk of noncompliance with a subaward to determine the appropriate subrecipient monitoring described in paragraph (f) of this section. When evaluating a subrecipient's risk, a pass-through entity should consider: 1) The subrecipient’s prior experience with the same or similar subawards; 2) The results of previous audits. This includes considering whether or not the subrecipient receives a Single Audit in accordance with subpart F and the extent to which the same or similar subawards have been audited as a major program; 3) Whether the subrecipient has new personnel or new or substantially changed systems; and 4) The extent and results of any Federal agency monitoring (for example, if the subrecipient also receives Federal awards directly from the Federal agency). Further, 2 CFR 200.332(e) states that a pass-through entity must monitor the activities of a subrecipient as necessary to ensure compliance with Federal statutes, regulations, and subaward terms and conditions and to ensure the goals and objectives of the subaward are achieved. At a minimum, monitoring must include: (1) Reviewing financial and performance reports; (2) Ensuring the subrecipient takes corrective action on significant developments that negatively affect the subaward (including relevant Single Audit findings, other audit findings, site visits, and written notifications of adverse conditions); (3) Issuing a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity, as required by § 200.521; and (4) Resolving audit findings specifically related to the subaward. Additionally, 2 CFR 200.332(f) states a pass-through must, depending upon the pass-through entity's assessment of the risk posed by the subrecipient (as described in 2 CFR 200.332(c)), the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: (1) Providing subrecipients with training and technical assistance on program-related matters; (2) Performing site visits to review the subrecipient's program operations; and (3) Arranging for agreed-upon-procedures engagements as described in 2 CFR 200.425. Also, 2 CFR 200.332(g) requires the pass-through entity to verify that a subrecipient is audited as required by Subpart F of Part 200. Lastly 2 CFR 200.303(a) states, recipient and subrecipients of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition During the year ended December 31, 2025 Bassett Health Network (the Network) passed through $166,774 of federal funding to subrecipients as it relates to the Research and Development Cluster. As part of our testing related to subrecipient monitoring, we identified the following: A. For 3 out of 3 subrecipients selected for testwork, the Network was unable to provide support evidencing the evaluation of the subrecipients’ fraud risk and risk of noncompliance risk. B. For 3 out of 3 subrecipients selected for testwork, the Network was unable to provide evidence of considering or performing additional monitoring procedures based on the subrecipient’s risk evaluation. C. For 3 out of 3 subrecipients selected for testwork, the Network was unable to provide evidence that the Network reviewed that the subrecipient receives a Single Audit in accordance with subpart F. Cause The cause of the condition was a lack of sufficiently documented and implemented policies, procedures, and internal controls to ensure that required subrecipient monitoring activities were performed and adequately documented in accordance with federal requirements. Effect Failure to perform annual risk assessments to determine appropriate subrecipient monitoring procedures, as well as failure to verify and review subrecipient Single Audit reports, may result in insufficient oversight to detect subrecipient noncompliance with Federal statutes, regulations, and the terms and conditions of the award. Further, the lack of timely audit reviews limits the Network’s ability to ensure subrecipients take prompt corrective action on significant developments or deficiencies affecting the subaward. Questioned Costs None. Recommendation We recommend the Network develop written policies and procedures to ensure that all required subrecipient monitoring activities, both identified through risk assessments and through review of Single Audits, are consistently performed and adequately documented in accordance with Federal requirements and the terms and conditions of the subawards. Such documentation should provide clear and sufficient evidence that required risk assessment and monitoring procedures have been completed, including documentation that demonstrates what was performed, when it was performed, who performed it, the results of the monitoring activities, and any follow‑up actions or issues identified, as applicable. View of Responsible Officials Recommendation accepted. Please see corrective action plan.

Corrective Action Plan

Reference: Finding Number 2025-001 - Subrecipient monitoring Audit of Awards U54OH007542, 23U01OH012656, R01OH011668, and U13OH01282 Research and Development Cluster (93.262) for audit period 01/01/2025–12/31/2025 Finding: During the year ended December 31, 2025 Bassett Health Network (the Network) passed through $166,774 of federal funding to subrecipients as it relates to the Research and Development Cluster. As part of our testing related to subrecipient monitoring, we identified the following: A. For 3 out of 3 subrecipients selected for testwork, the Network was unable to provide support evidencing the evaluation of the subrecipients’ fraud risk and risk of noncompliance risk. B. For 3 out of 3 subrecipients selected for testwork, the Network was unable to provide evidence of considering or performing additional monitoring procedures based on the subrecipient’s risk evaluation. C. For 3 out of 3 subrecipients selected for testwork, the Network was unable to provide evidence that the Network reviewed that the subrecipient receives a Single Audit in accordance with subpart F. Recommendation: We recommend the Network develop written policies and procedures to ensure that all required subrecipient monitoring activities, both identified through risk assessments and through review of Single Audits, are consistently performed and adequately documented in accordance with Federal requirements and the terms and conditions of the subawards. Such documentation should provide clear and sufficient evidence that required risk assessment and monitoring procedures have been completed, including documentation that demonstrates what was performed, when it was performed, who performed it, the results of the monitoring activities, and any follow‑up actions or issues identified, as applicable Management Comments: We agree with the finding and observations and specifically note the following corrective actions will be implemented: Corrective Action Plan: Sub Award Monitoring: The Office of Grants Management will ensure that all investigators receiving grant funds will be provided Policy GM-MC-BMC-021 Sponsored Projects Sub-Awards. Principle Investigators and Project Directors will be responsible for monitoring sub awardees in accordance with the policy and 2 CFR: 200.330-200.332. This process will also include a subrecipient pre-award acceptance form that requires affirmation to audit compliance and the most recent single audit submission prior to final contract approval. This revised process will be begin to be put in place starting 11/1/2026.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1239308 2025-001
    Material Weakness Repeat
  • 1239309 2025-001
    Material Weakness Repeat
  • 1239310 2025-001
    Material Weakness Repeat
  • 1239311 2025-001
    Material Weakness Repeat
  • 1239312 2025-001
    Material Weakness Repeat
  • 1239313 2025-001
    Material Weakness Repeat
  • 1239314 2025-001
    Material Weakness Repeat
  • 1239315 2025-001
    Material Weakness Repeat
  • 1239316 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.247 ADVANCED NURSING EDUCATION WORKFORCE GRANT PROGRAM $456,412
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $112,147
93.778 GRANTS TO STATES FOR MEDICAID $95,509
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $71,102
93.361 NURSING RESEARCH $61,029
93.866 AGING RESEARCH $57,374
93.879 MEDICAL LIBRARY ASSISTANCE $57,041
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $50,000
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $30,000
93.301 SMALL RURAL HOSPITAL IMPROVEMENT GRANT PROGRAM $13,832
93.767 CHILDREN'S HEALTH INSURANCE PROGRAM $12,286
66.716 RESEARCH, DEVELOPMENT, MONITORING, PUBLIC EDUCATION, OUTREACH, TRAINING, DEMONSTRATIONS, AND STUDIES $3,418
93.262 OCCUPATIONAL SAFETY AND HEALTH PROGRAM $3,123