Finding Text
Finding 2021-008
Program: Office for Coastal Management
Federal Financial Assistance Listing: 11.473
Federal Grantor: U.S. Department of Commerce
Passed-through: National Fish and Wildlife Foundation
Award No. and Year: 0318.19.070225 (2020)
Compliance Requirements: Subrecipient Monitoring
Type of Finding: Material Non-Compliance/Material Weakness
Criteria:
2 CFR Part 200.331(a) - Requirements for Pass-Through Entities, states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the 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 award.
Condition:
The following information was not identified at the time of subaward for three of the three subawards selected for testing from the Office for Coastal Management:
• Federal Award date by the Federal Agency
• Whether or not the award was R&D
• The indirect cost rate for the Federal Award (including if the de minimus rate is charged)
Questioned Costs:
No questioned costs were identified as a result of our procedures.
Context/Sampling:
Sampling was not used. We selected all three subrecipients for testing. The condition noted above was identified during our procedures over CFSC’s subrecipient monitoring provisions.
Repeat Finding from Prior Year:
No
Effect:
CFSC did not identify the required elements of the subaward to the subrecipients at the time of subaward, increasing the risk of noncompliance.
Cause:
CFSC’s procedures did not consistently ensure that the required award information and applicable requirements were communicated to subrecipients.
Recommendation:
We recommend that CFSC modify and strengthen its current policies and procedures to ensure that all required award information and applicable requirements are communicated to subrecipients at the time of subaward in accordance with 2 CFR section 200.331(a).
Views of Responsible Officials and Planned Corrective Actions:
See Separate Corrective Action Plan.