Finding Text
Federal Programs – AL 93.569 – Community Services Block Grant
Criteria – Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (CAPND) must perform certain activities to ensure that the subrecipient
uses the funds within provisions of the grant award and Uniform Guidance (2 CFR sections
200.331 (d) through (f)). This includes the review of independent audits of subrecipients and
response to deficiencies detected through audits (2CFR section 200.331 (f)). It also includes
requiring all subawards granted to subrecipients have specific identifications with the award to
ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition – For the year ended December 31, 2023, we reviewed CAPND's subrecipient
monitoring policy, requested supporting documentation for monitoring activities included, and
interviewed key members of management when documentation was not available. Performance
of several of the policies noted as required under Uniform Guidance for subrecipient monitoring
and per CAPND's internal policies could not be substantiated or were determined to not have
occurred during the year under audit.
Cause – Due to internal control deficiency noted in 2023-002, the subrecipient monitoring
requirement was not in compliance during the current year.
Context– Of the total federal expenditures under the program noted above, $276,165 are
passed through to subrecipients. The following are specific items noted that were not in
compliance with the criteria listed above:
- We requested copies of the correspondence with subrecipients requesting copies of the
financial statement audits performed in compliance with 2 CFR 200. Follow up
discussion with CAPND staff confirmed that this requirement was not completed during
the year under audit. Subsequently, of the five subrecipient audit reports required to be
requested, zero were requested.
- We requested copies of all subawards awarded to subrecipients. Of the five subawards
awarded to pass-through entities, all five were missing the following required information
under (2 CFR Section 200.331(a)):
o Subrecipient's unique entity identifier.
o Amount of federal funds obligated by this action by the pass-through entity to the
subrecipient.
Effect – Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Question costs – None.
Repeat Finding – This is not a repeat finding.