Finding Text
Finding 2022-001 Significant deficiency in internal controls over compliance and instances of noncompliance related to subrecipient monitoring. Federal Agency: Department of the Treasury Program Title: Coronavirus State and Local Fiscal Recovery Fund Assistance Listing: 21.027 Award Number: DA21-2000 Award Period: October 1, 2021 - December 31, 2022 Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) Subpart D (as codified by the Department of Treasury in CFR OPEN) require a pass-through entity to adopt compliance policies, include certain provisions in subaward agreements, and evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of such agreements for the purposes of determining appropriate subrecipient monitoring. Condition/Context for Evaluation In a population of three subrecipients, the subaward agreements did not include all required provisions outlined in 2 CFR 200.332. Additionally, the Organization?s subrecipient monitoring policy did not include a provision requiring a formal documented risk assessment, and as such no documentation was available showing an assessment of the risk of noncompliance of the subrecipients. Monitoring was performed over all subrecipients as noted in the Organization?s policy. Effect or Potential Effect The Organization did not fully comply with the requirements regarding subaward agreements and evaluating each subrecipients risk of noncompliance for the purposes of determining the appropriate subrecipient monitoring. Questioned Costs Not Applicable Cause Internal controls were not effective in ensuring that the Organization?s subrecipient monitoring policies were in compliance with the Uniform Guidance requirements. Repeat Finding No Recommendation We recommend that the Organization update the subrecipient monitoring policy to ensure subaward agreements include all necessary provisions and documentation of risk assessment is retained. Views of Responsible Officials of Auditee Management agrees with the finding and has provided the accompanying corrective action plan.