Finding 477879 (2023-003)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-07-08

AI Summary

  • Core Issue: The Institute lacks specific monitoring procedures for subrecipients based on their risk level, leading to potential noncompliance with federal requirements.
  • Impacted Requirements: Failure to include necessary federal award information, such as the Federal Assistance Listing Number, in subaward agreements violates § 200.332.
  • Recommended Follow-Up: Revise subaward policies to incorporate risk-based monitoring procedures and ensure all agreements meet federal documentation requirements.

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.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 477873 2023-001
    Significant Deficiency
  • 477874 2023-002
    Significant Deficiency
  • 477875 2023-003
    Significant Deficiency
  • 477876 2023-004
    Significant Deficiency
  • 477877 2023-001
    Significant Deficiency
  • 477878 2023-002
    Significant Deficiency
  • 477880 2023-004
    Significant Deficiency
  • 1054315 2023-001
    Significant Deficiency
  • 1054316 2023-002
    Significant Deficiency
  • 1054317 2023-003
    Significant Deficiency
  • 1054318 2023-004
    Significant Deficiency
  • 1054319 2023-001
    Significant Deficiency
  • 1054320 2023-002
    Significant Deficiency
  • 1054321 2023-003
    Significant Deficiency
  • 1054322 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $645,202
15.629 Great Apes Conservation Fund $111,416
19.705 Trans-National Crime $109,035