Finding Text
2022-002 Subrecipient Monitoring, Significant Deficiency in Internal Controls over Compliance and Instance of Noncompliance Criteria: Under Title 2 U.S. Code of Federal Regulations Part 200.331, all pass-through entities must evaluate and document each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring as required by 200.331(b). Condition/Context: Per review of the subrecipient files for Coronavirus State and Local Recovery Funds assistance listing number 21.027, we noted both of the files tested out of a total population of four subrecipients did not document risk assessment. Cause: Lack of oversight of Federal Requirements related to subrecipient monitoring and documentation requirements for risk assessment contributed to this finding. Effect: The County is not in compliance with Federal requirement as outlined in 2 CFR 200 Section 200.331. Question costs: None. Repeat finding: No. Recommendation: We recommend internal controls be reviewed and updated to ensure that the County is in compliance with the Title 2 U.S. Code of Federal Regulation requirements for all subrecipient awards. Management?s Response: Management of Josephine County has acknowledged that evidence of subrecipient monitoring and risk assessments were not retained in the file. While vetting was done on subrecipients a risk assessment form was not formally written. We have addressed it by providing training to central staff as well as department staff who have responsibility over grants. Further, a dedicated staff member will be responsible for monitoring grant compliance and completing risk assessments that were not done based on the vetting process that did occur.