Finding 1240078 (2026-001)

Condition: We noted that the Foundation did not include all information required by Code of Federal Regulations (“CFR”) section 200.332 in subaward agreements selected for testing. Specific required information omitted from the subaward agreements included the following: the subrecipients unique entity identifier; the assistance listing title and number; identification of whether the federal award is for research and development; the indirect cost rate for the federal award; a specific statement stating that the subrecipient permits the pass-through entity & auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements; and appropriate terms and conditions concerning the closeout of the subaward. Criteria: CFR 200.332 requires specific language and informational content be included in all subaward agreements. Cause: The subaward agreements reference compliance with terms and conditions of the Foundation’s EDA grant agreement, rather than explicitly stating the subrecipient requirements, defined in CFR 200.332. Also, the policies and procedures manual of the Foundation does not include language requiring the inclusion of all specified information included in CFR section 200.332. Effect: Underlying executed subaward agreements are not in compliance with the Uniform Guidance and could lead to subrecipients not complying with all pertinent federal program requirements. Perspective Information: The errors were identified in two of the two items selected for testing from a total population of four. Recommendation: We recommend that the Foundation include required information in all future subaward agreements. We also recommend that the Foundation update their Policies and Procedures manual to reflect these current requirements and ensure proper inclusion in future subaward agreements. View of Responsible Officials and Planned Corrective Action: In agreement. The Foundation has begun issuing addenda to their existing subrecipient agreements to include the above information to ensure compliance with CFR section 200.332.