Finding Text
Reference Number: 2023-002 – Significant Deficiency, Subrecipient Monitoring
Criteria: Pass through entities must clearly identify to the subrecipient: (1) the award as a subaward
at the time of subaward (or subsequent subaward modification) by providing the information
described in 2 CFR section 200.332(a)(l); (2) all requirements imposed by the PTE on the
subrecipient so that the federal award is used in accordance with federal statutes, regulations, and
the terms and conditions of the award (2 CFR section 200.332(a)(2)); and (3) any additional
requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own
responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section
200.332(a)(3)).
Condition: The contracts between the Council and its subrecipients did not identify the correct
federal find source to its subrecipient as prescribed by 2 CFR Section 200.332.
Cause: Historically, the Council has always received funding from the Department of Justice through
the State of Texas. During 2023, grant award notifications indicated that the source of funding was
the Department of Treasury under Assistance Listing Number 21.027, identified as Coronavirus
State Fiscal Recovery Fund (Victims of Crime -SB 8). Controls in place did not allow the Council to
notice that the funding source had changed and continued to inform its subrecipients that the federal
funds came from the Department of Justice.
Effect: The Council's subrecipients may not have timely or accurate information to determine the
applicability of certain compliance requirements under the Uniform Guidance specific to the
applicable Assistance Listing Number.
Recommendation: Management should update policies and procedures to ensure that relevant staff
are aware of funding sources and compliance requirements with respect to those sources.
Management should update its sub-grant templates to ensure that required information is
communicated to subrecipients.
Management Response: See management’s corrective action plan.