Finding 1239655 (2025-004)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-09-30
Audit: 414322
Organization: 9/11 Day (CA)
Auditor: EIDE BAILLY

AI Summary

  • Core Issue: There are significant weaknesses in internal controls over compliance related to subrecipient monitoring, as outlined in 2 CFR 200.332.
  • Impacted Requirements: Key compliance elements were missing in subawards, fraud risk assessments were inadequate, and necessary documentation for subgrantee evaluations was not maintained.
  • Recommended Follow-Up: Management should thoroughly review and implement the subrecipient monitoring requirements in 2 CFR 200.332 and establish a comprehensive monitoring policy.

Finding Text

Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Subrecipient Monitoring Material Weakness in Internal Controls over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.332 identifies the requirements for all pass-through entities surrounding subrecipient monitoring and management. Condition: We noted the following during testing; a) Subawards did not contain minimum required elements in accordance with 2 CFR 200.332(b) b) The Organization did not consider all suggested elements when evaluating subgrantee’s fraud risk and risk of noncompliance with subaward in accordance with 2 CFR 200.332(c) c) Documentation could not be provided to substantiate whether suspension and debarment was considered prior to awarding the subgrant d) The Organization required the subgrantee to complete performance reports, however, did not require completion of a financial report in accordance with 2 CFR 200.332(e)(1) e) The Organization did not consider whether subgrantee was required to be audited and therefore did not review whether subgrantee had deficiencies reported over the federal program in accordance with 2 CFR 200.332(e)(2) through 2 CFR 200.332(e)(4) Cause: Management was not familiar with all subrecipient monitoring requirements as published under 2 CFR 200.332. The Organization adopted a subrecipient monitoring policy during quarter 4 of 2025. Effect: Without full understanding of subrecipient monitoring requirements under 2 CFR 200.332, demonstrating that the program complies with laws, regulations, and other compliance requirements is difficult. Questioned Costs: None reported. Context/Sampling: Seven out of thirty six subrecipients were reviewed for testing. Repeat Finding from Prior Year: Yes, prior year finding 2024-005. Recommendation: We recommend management to review subrecipient monitoring requirements as published under 2 CFR 200.332 and adopt a subrecipient monitoring policy. Views of Responsible Officials: Management is in agreement.

Corrective Action Plan

Federal Agency Name: Corporation for National and Community Service Federal Financial Assistance Listing #94.012 Program Name: September 11th National Day of Service and Remembrance Grants Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Subawards did not contain minimum required elements in accordance with 2 CFR 200.332. The organization did not consider all suggested elements when evaluating subgrantee’s fraud risk and risk of noncompliance with subaward in accordance with 2 CFR 200.332(c). Documentation couldn’t be provided to substantiate whether suspension and debarment was considered prior to awarding subgrant. The organization required the subgrantee to complete performance reports, however, did not require completion of a financial report in accordance with 2 CFR 200.332(e)(1). The organization did not consider whether subgrantee was required to be audited and therefore did not review whether subgrantee had deficiencies. Corrective Action Plan: Management agrees with the finding and has begun implementing enhanced subrecipient monitoring procedures designed to address each of the identified compliance requirements. Subaward agreements will be revised to include the applicable information and terms required by 2 CFR §200.332. Prior to issuing subawards, management will verify and retain documentation of each prospective subrecipient's suspension and debarment status and will determine whether the subrecipient is subject to Single Audit requirements. Management will review available audit information, including identified findings or deficiencies, when applicable. Management is also enhancing its pre-award risk assessment process to evaluate each prospective subrecipient's risk of noncompliance with the federal subaward. The revised process will incorporate documented risk factors, including prior experience with the same or similar subawards, results of previous audits or other available financial oversight information, personnel and systems used to administer federal awards, and other factors relevant to the subrecipient's ability to comply with federal requirements. The results of the risk assessment will be documented and used to determine the appropriate level and nature of subrecipient monitoring. Subrecipients will be required to submit both programmatic and financial reports during the period of performance. Management will document its review of required reports and will perform additional monitoring, including desk reviews or other procedures, as appropriate based on assessed risk and performance. These procedures will be incorporated into the organization's documented subrecipient monitoring process and retained with the applicable grant records. Responsible Individuals: David Paine - President, Dominique Carver – Operations Director, Miranda Cirtwell – Controller Anticipated Completion Date: February 15, 2026

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1239653 2025-002
    Material Weakness Repeat
  • 1239654 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
94.012 AMERICORPS SEPTEMBER 11TH NATIONAL DAY OF SERVICE AND REMEMBRANCE GRANTS 94.012 $1.80M