Finding Text
PASS-THROUGH GRANTOR: Direct Grant FEDERAL AGENCY: U.S. Department of Treasury ASSISTANCE LISTING: 21.027 FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) FEDERAL AWARD YEAR: 2021 CONTROL CATEGORY: Subrecipient Monitoring QUESTIONED COSTS: $-0- Condition: During our audit, it was noted the County had one (1) subrecipient, the City of Wagoner, which received $278,000 of the Coronavirus State and Local Fiscal Recovery Funds. The County did not obtain subrecipient agreements containing all required elements as required by 2 CFR 200.332. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with compliance requirements. Effect of Condition: This condition resulted in noncompliance with grant requirements and could lead to a loss of federal funds to the County. Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. Management Response: BOCC Chairman and County Clerk: Upon OSAI’s recommendation, we are putting into place protocols in an official policy and procedures manual specific to all Federal Grants. With their guidance, future Federal Grants will be better documented and monitored in accordance with this policy. Criteria: 2 CFR 200 §200.332 Requirement for Pass-Through Entities states in part: All pass-through entities must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward. (2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award. (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the passthrough entity to meet the requirements of this part. (6) Appropriate terms and conditions concerning closeout of the subaward.