Finding Text
Finding 2022-015 – Noncompliance with Subrecipient Monitoring Over Federal Grant – Coronavirus State and Local Fiscal Recovery Funds
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Subrecipient Monitoring
QUESTIONED COSTS: $404,258
Condition: During our audit it was noted the County had three (3) subrecipients of the Coronavirus State and Local Fiscal Recovery Funds, in which the county does not have a subrecipient monitoring policy, and the County did not obtain subrecipient agreements comprising the following information:
• Subrecipient name.
• Subrecipient Authorized Representative and program contact information.
• Subrecipient Employee Identification Number (EIN) and DUNS number.
• Federal Award Identification Number (FAIN).
• Name of Federal Awarding Agency.
• Contact information for the official at the Federal Awarding Agency.
• Catalog of Assistance Listing (AL) number and name.
• Federal award date.
• Total amount of the federal award and Indirect Cost Rate.
• Federal award project description.
• Start and end date of the agreement.
• Amount of federal funds budgeted for the agreement and Indirect Cost Rate allowed.
• A statement that all activities must be in accordance with federal statutes, regulations, and terms and conditions of the federal award. The sub recipient should receive a copy of the award documents.
• A detailed description of any additional requirements you want the subrecipient to be responsible for such as performance and/or financial reports, attending meetings and/or trainings etc.
• A statement about the monitoring activities, such as where/when they will take place; also include a statement indicating the subrecipient will collaborate on monitoring activities including providing requested financial documents.
• A statement indicating if any of the items in the agreement change during the period of performance, the agreement will be amended.
• Provide close out terms and conditions.
In addition, it was noted the County did not verify the subrecipients were not suspended or debarred.
Further, it was noted the county expended the funds to the subrecipients before receiving the proper documentation and the county paid subrecipients $83,546 more than documentation received.
Comanche County Fairgrounds Trust Authority $ 12,881
Comanche County Facilities Authority 70,665
Total undocumented: $ 83,546
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.
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:
Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.
Criteria: 2 CFR 200, §200.332 Requirements 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 pass-through entity to meet the requirements of this part.
(6) Appropriate terms and conditions concerning closeout of the subaward.