Finding 371614 (2020-011)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2020
Accepted
2024-03-01

AI Summary

  • Core Issue: Federal funds were disbursed before formal subrecipient agreements were signed, violating grant agreement criteria.
  • Impacted Requirements: Title 31, Subtitle V, §6304 mandates agreements must be in place before transferring funds to ensure compliance.
  • Recommended Follow-Up: Management should create a plan to ensure all subrecipient agreements are executed prior to any fund disbursement.

Finding Text

1. Criteria: In title 31, Subtitle V, §6304. Using grant agreements, establishes that “An executive agency shall use a grant agreement as the legal instrument reflecting a relationship between the United States Government and a State, a local government, or other recipient when— (1) the principal purpose of the relationship is to transfer a thing of value to the State or local government or other recipient to carry out a public purpose of support or stimulation authorized by a law of the United States instead of acquiring (by purchase, lease, or barter) property or services for the direct benefit or use of the United States Government; and (2) substantial involvement is not expected between the executive agency and the State, local government, or other recipient when carrying out the activity contemplated in the agreement.” Condition: From a sample of sixty (60) subrecipient agreements, forty-seven (47) had payments before the date the subrecipient agreement were signed, as follows: Cause: The Authority did not execute the subrecipient agreements before to disbursing the federal funds. Effects: Disburement of federal funds without formal subrecipient agreements would lead to noncompliance event. Questioned Costs: None. Recommendation: We recommend management to implement a plan to ascertain compliance with required procedures to perform agreements with subrecipients before disbursements commence.

Corrective Action Plan

Corrective Action Plan: During the year 2021, COR3 set up a team specifically aimed at working on centralizing the Subaward Agreements. This, in order to create an automated procedure for the Subaward process and establish a physical and digital file that contains the handling of said documents. At the moment, all Amended subawards that were not delivered in 2020-2021 are being updated as of June30,2022 and sent to the applicants to be returned duly completed and signed to ensure compliance with federal requirements. With the purpose of improving and optimizing the procedures, the work was done in collaboration with our software consultant on the implementation of an automated system to create uniformity and streamline processes. Contact Person: Sebastian Batista, Legal Director Anticipated Completion Date: September 30, 2023

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 371606 2020-003
    Significant Deficiency Repeat
  • 371607 2020-004
    Significant Deficiency
  • 371608 2020-005
    Significant Deficiency
  • 371609 2020-006
    Significant Deficiency Repeat
  • 371610 2020-007
    Significant Deficiency
  • 371611 2020-008
    Significant Deficiency Repeat
  • 371612 2020-009
    Significant Deficiency Repeat
  • 371613 2020-010
    Significant Deficiency Repeat
  • 948048 2020-003
    Significant Deficiency Repeat
  • 948049 2020-004
    Significant Deficiency
  • 948050 2020-005
    Significant Deficiency
  • 948051 2020-006
    Significant Deficiency Repeat
  • 948052 2020-007
    Significant Deficiency
  • 948053 2020-008
    Significant Deficiency Repeat
  • 948054 2020-009
    Significant Deficiency Repeat
  • 948055 2020-010
    Significant Deficiency Repeat
  • 948056 2020-011
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $632.66M
93.982 Individual Assistance Program - Crisis Counseling Assistance & Training Program $3.22M
97.039 Hazard Mitigation Grant $225,000
97.047 Pre-Disaster Mitigation $19,379