Finding 44499 (2022-001)

Significant Deficiency Repeat Finding
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-04-23

AI Summary

  • Core Issue: LAHSA lacks adequate internal controls to monitor subrecipients, failing to oversee 1 out of 8 tested, which poses compliance risks.
  • Impacted Requirements: The agency did not follow necessary monitoring procedures as outlined in 2 CFR sections 200.332(d) through (f), leading to potential noncompliance.
  • Recommended Follow-Up: LAHSA should establish a policy to regularly review and update the subrecipient monitoring plan to ensure all contracts are assessed and monitored appropriately.

Finding Text

2022 ? 001 Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus Relief Fund Assistance Listing Number: 21.019 Federal Award Identification Number and Year: SLT0198 Pass-Through Agency: County of Los Angeles Pass-Through Number: Unknown Award Period: March 1, 2020 through December 31, 2021 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: A pass-through entity (PTE) must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals (2 CFR sections 200.332(d) through (f)). In addition to procedures identified as necessary based upon the evaluation of subrecipient risk or specifically required by the terms and conditions of the award, subaward monitoring must include the following: ? Reviewing financial and programmatic (performance and special reports) required by the PTE. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the federal award provided to the subrecipient from the PTE detected through audits, on-site reviews, and other means. ? Issuing a management decision for audit findings pertaining to the federal award provided to the subrecipient from the PTE as required by 2 CFR section 200.521. Condition: During our testing, we noted LAHSA did not have adequate internal controls designed to properly monitor its? subrecipients. Questioned costs: Unable to determine. Context: During our testing of subrecipient monitoring, it was noted that LAHSA did not monitor 1 out of 8 subrecipients tested. The subrecipient received $169,035 for the fiscal year ended June 30, 2022. Cause: LAHSA's new subrecipient monitoring process was not implemented until January 2022. At that time, the subrecipients that were not monitored did not have an active contract with federal funding. As such, they were deemed to be low risk. LAHSA does not have a policy in place to ensure that the subrecipient monitoring plan and risk assessment is revisited throughout the year to ensure new contracts are assessed and monitored appropriately. Effect: LAHSA did not perform required monitoring over subrecipients of federal funding. The lack of internal controls over this compliance requirement provides an opportunity for noncompliance by subrecipients of the grant. Repeat Finding: Yes. Recommendation: We recommend LAHSA implements controls to ensure that the subrecipient monitoring plan is revisited at the time contracts are entered into in order to ensure proper coverage. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

2022-001 Coronavirus Relief Fund ? Assistance Listing No. 21.019 Recommendation: We recommend LAHSA implements controls to ensure that the subrecipient monitoring plan is revisited at the time contracts are entered into in order to ensure proper coverage. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: LAHSA acknowledges that there is an opportunity to enhance its current subrecipient monitoring procedures. LAHSA conducts risk-based monitoring reviews of our subrecipients. Our FY 21- 22 Annual Monitoring Plan describes how LAHSA oversees the monitoring selection of our subrecipients, depending on the complexity of their activity, subrecipients? monitoring could be more frequent. It should be noted that LAHSA?s monitoring plan is inclusive of multiple LAHSA funding streams and programs. Additionally, the annual monitoring plan endeavors to alleviate any duplication of efforts. Subrecipients are selected for review based on Monitoring Priorities established each Fiscal Year. Moreover, since the onset of COVID-19, Monitoring and Compliance (M&C) now Grants Management and Compliance (GMC) shifted our monitoring efforts to help stand up Project Room Key, our compliance responsibilities were bifurcated between our grants management side of the house, whose core focus/activities were remote, and the compliance side of the house which implements more intensive monitoring which include onsite visits. During FY 21-22, monitoring was reduced to cover high risk and urgent priorities. All agencies selected for monitoring will have analysis conducted to review agencies risk assessment results, spending trends, and performance data on an on-going basis throughout the FY. This analysis will help identify if the risk assessment was accurate and if the activities of the agency need additional review. Moving forward, LAHSA acknowledges the opportunity to enhance monitoring and will conduct 100% monitoring of subrecipients that receive federal funds. We will bring the monitoring plan to a future Audit and Risk committee meeting. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Samson, Deputy Chief Financial & Administrative Officer, jsamson@lahsa.org; Amy Williams, Director ? Grants Management & Compliance, awilliams@lahsa.org Planned completion date for corrective action plan: To be implemented effective in FY 22-23.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 620941 2022-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
14.231 Emergency Solutions Grant Program $100.18M
14.267 Continuum of Care Program $27.81M
21.019 Coronavirus Relief Fund $14.12M
93.558 Temporary Assistance for Needy Families $11.81M
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $934,684
14.218 Community Development Block Grants/entitlement Grants $152,000