Finding Text
Finding # 2023-003 Subrecipient Monitoring (Significant Deficiency)
Information on the Federal Programs: Assistance Listing #98.001 USAID Foreign Assistance for
Programs Overseas
Criteria or Specific Requirement: § 200.332, Requirements for pass-through entities, requires
pass-through entities to evaluate each subrecipient's risk of noncompliance with federal statutes,
regulations, and the terms and conditions of the subaward for purposes of determining the
appropriate subrecipient monitoring. The statute also requires pass-through entities to include
certain federal award identifying information within the subaward agreement.
Condition: The Institute maintains subaward selection and monitoring policies. However, the
policies do not include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. Additionally, as part of our audit, we selected a sample of
subawards charged to the major federal programs. We noted that a subaward agreement did not
contain certain federal award identifying information, specifically the relevant Federal Assistance
Listing Number (ALN).
Cause: The Institute maintains subaward selection and monitoring policies that do not include preprescribed
monitoring procedures based on an assessed level of risk. Additionally, Federal
Assistance Listing Number were omitted from the subaward agreements based on an oversight
during the subaward writing process.
Effect or Potential Effect: The Institute may have inadvertently failed to perform monitoring
procedures appropriate for a subrecipient’s assessed level of risk. Not including Federal Assistance
Listing Numbers in the subaward agreement could lead to the subrecipient omitting the subaward
from its Schedule of Expenditures of Federal Awards.
Questioned Costs: N/A
Context: The Institute executes subaward agreements under US Federal grants. Therefore, the
Institute is subject to § 200.332 Requirements for pass-through entities. Our audit procedures
consisted of testwork completed on subawards charged to the federal awards. The report in which
samples were selected was generated directly from the Institute’s general ledger (accounting
system). We consider our sample to be representative of the population.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that the Institute revise its subaward selection and monitoring
policies to include pre-prescribed monitoring procedures based on an assessed level of risk
assigned in the subaward selection stage. The assessed level of risk should be documented in a
pre-award risk assessment. Additionally, we recommend that the Institute ensure that all subaward
agreements include all elements required by §200.332.