Finding Text
Subrecipient Monitoring
Finding Type: Significant Deficiency in Internal control over compliance and noncompliance
Federal Program Title and AL Number: Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (93.323).
Criteria: The Uniform Guidance in 2 CFR Section 200.332 (b) states that pass-through entities must “evaluate 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.”
Condition and context: The Organization did not have a subrecipient risk assessment process in place that corresponded with a risk-based monitoring plan.
Cause: The Organization’s internal controls did not ensure compliance with 2 CFR Section 200.332.
Effect: The Organization did not comply with subrecipient monitoring requirements.
Questioned Costs: Questioned costs are not able to be determined.
Repeat finding: No.
Recommendation: We recommend that the Organization implement a formal risk assessment process to monitor its subrecipients.
Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan.