Finding 397942 (2022-003)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2024-05-20
Audit: 306649
Organization: Alianza Americas (IL)

AI Summary

  • Core Issue: Subrecipient monitoring was not conducted as required by the Uniform Guidance, leading to non-compliance.
  • Impacted Requirements: Failure to adhere to monitoring standards outlined in 45 CFR 75.351 to 75.353, affecting internal controls over federal awards.
  • Recommended Follow-Up: Update policies and procedures to ensure proper subrecipient monitoring and provide timely training for staff.

Finding Text

Finding 2022-003, Subrecipient Monitoring - Repeat Finding 2021-003 Federal Agency: U.S. Department of Health and Human Services Program Name: Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Assistance Listing #: 93.318 Questioned Costs: None Condition/Context: Our audit procedures revealed that subrecipient monitoring was not performed in accordance with standards set forth in the Uniform Guidance. Criteria The Department of Health and Human Services recipients (i.e., Alianza Americas) to ensure monitoring of any subrecipient using federal funds to be consistent with the subrecipient monitoring standards set forth in the Uniform Guidance at 45 CFR 75.351 through 45 CFR 75.353, as applicable. In addition, Uniform Guidance requires that non-Federal entities establish and maintain internal control over the federal awards that provides reasonable assurance that the non-Federal entities are managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause The Organization did not monitor and review subrecipient activities in accordance with Uniform Guidance. The Organization's personnel were not trained timely to perform subrecipient monitoring in accordance with Uniform Guidance. Effect The Organization did not comply with Title 45 of the Code of Federal Regulations (CFR) Part 75 as it relates to subrecipient monitoring requirements. Recommendation We recommend that the Organization performs subrecipient monitoring in accordance with Uniform Guidance and that it updates its Policies and Procedures for Financial Management to include subrecipient monitoring process in accordance with Uniform Guidance. Organization's Management Response See corrective action plan.

Corrective Action Plan

MANAGEMENT’S CORRECTIVE ACTION PLAN ALIANZA AMERICAS For The Year Ended December 31, 2022 Finding 2022-003 Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Program Name: Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Assistance Listing #: 93.318 Questioned Costs: None Corrective Action: We agree with the auditor’s comments and actions stated in the recommendation. The Organization has updated its Program Operating and Fiscal and Accounting Policies and Procedures manuals to ensure consistent standards in monitoring of subrecipients’ financial and performance management. Additionally, the Organization counts on the support of a consultant with 16+ years of experience in managing federal awards. They are currently working with the organization to develop tools that will ensure a thorough process for subrecipient monitoring. This will include a process to ensure that proper risk assessment/ management is considered, during both pre- and post-award phases, to ensure the monitoring of any subrecipient using federal funds is consistent with the subrecipient monitoring standards set forth in the Uniform Guidance at 45 CFR § 75.351 through 45 CFR 75.353 and 2 CFR § 200.332, as applicable. To ensure improved compliance in this area, the organization will implement new Monitoring Tool and Corrective Action templates/ procedures to be utilized by Alianza Americas. These monitoring tools document subrecipient compliance, areas of concern and/or corrective action, needs for training/technical assistance, and the review of subrecipients’ financial, administrative, and programmatic policies, procedures, and overall performance. Contact Person: Oscar Chacon, Executive Director Anticipated Completion Date: June 30, 2024

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 397941 2022-002
    Significant Deficiency Repeat
  • 974383 2022-002
    Significant Deficiency Repeat
  • 974384 2022-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $2.57M
93.011 National Organizations of State and Local Officials $717,126