Finding Text
Finding 2022-001 ? M. Subrecipient Monitoring Identification of the Federal Program: Grantor: Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No. / FAIN: 93.847 / R24DK106743 Criteria or Specific Requirement: M. Subrecipient Monitoring ? A pass-through entity must evaluate each subrecipient?s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.332(b)). Condition: Management should establish and implement a policy which addresses the requirement identified above, including evaluating the results of previous audits obtained by its subrecipients including whether or not the subrecipient receives a single audit in accordance with 2 CFR part 200, subpart F, and the extent to which the same or similar subaward has been audited as a major program. Cause: Management implemented updated policies related to subrecipient monitoring during 2022; however, such policies were not in effect for the full calendar year. Effect or Potential Effect: The lack of an effective control over subrecipient monitoring resulted in instances of noncompliance identified. Questioned Costs: Not applicable. Context: In a sample of two subrecipients within the Research and Development Cluster, two instances of noncompliance were identified where it could not be ascertained that the Institute verified that subrecipients have been audited as required by 2 CFR part 200, subpart F, as Institute management did not evaluate the subrecipients? compliance. Identification as a repeat finding: This finding was reported as finding 2021-001 in the prior year. Recommendation: Management has implemented a policy over subrecipient monitoring during 2022. Management should therefore perform an annual review of Uniform Guidance grant compliance audit reports of subrecipients on an annual basis to identify and evaluate the subrecipients? risk of noncompliance for purposes of determining the appropriate subrecipient monitoring. Views of Responsible Officials: Management concurs with this audit finding. During 2022, management implemented an annual review control whereby the reports will be reviewed to ensure compliance with federal agency requirements.