Finding 479539 (2023-002)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-07-29
Audit: 316094
Organization: Accountability Lab, Inc. (DC)

AI Summary

  • Core Issue: Accountability Lab lacks a formal process to verify if subrecipients are audited as required by federal regulations.
  • Impacted Requirements: Failure to comply with 2 CFR 200.332(f) regarding subrecipient audit verification.
  • Recommended Follow-Up: Implement an annual "Review of Subrecipient Audit" form to track compliance and review audit reports for each subrecipient receiving U.S. Government funds.

Finding Text

Finding 2023-002: Subrecipient Monitoring - Review of Audit Reports Information on the Federal Program: Assistance Listing Numbers 19.705 and 19.345 Criteria: As stated in 2 CFR 200.332(f), all pass-through entities must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold for triggering such an audit. Condition: We were unable to determine whether Accountability Lab performed procedures to verify whether or not its subrecipients were subject to a compliance audit in accordance with 2 CFR 200 Subpart F. Cause: Accountability Lab does not have a formal/regularized process in place to monitor subrecipient audit requirements. Effect: Accountability Lab's current practices do not provide sufficient documentation to demonstrate its compliance with the requirements to obtain and review subrecipient audit reports. Questioned Costs: None noted. Context: Our audit work included three subrecipients across two major programs. For two out of the three subrecipients tested, we were not able to verify whether or not Accountability Lab obtained and reviewed the subrecipient audit reports. Identification as a Repeat Finding: Not applicable. Recommendation: Accountability Lab should implement a "Review of Subrecipient Audit" form, to be completed annually for each subrecipient that receives U.S. Government funding. The form should document a) the subrecipient's name; b) the annual amount of U.S. Government funds expended by the subrecipient; c) whether the subrecipient was subject to a U.S. Government compliance audit under 2 CFR 200 Subpart F; and d) Accountability Lab's formal review of the audit report as well as its conclusions and follow up on any reported findings, if applicable.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: AL has a long-standing preassessment Questionnaire (sample attached) that we require each potential subgrantee to complete before they can receive any financial remuneration from us. In response to this finding, we will require all subgrantees to complete this questionnaire on an annual basis. In addition we have included the following questions to the questionnaire:  Does the organization perform an annual audit of financial statements?  Annual amount of US Government Funds received?  Is the organization subject to a US compliance audit under 2 CFR 200 Subpart F?  If the organization is subject to a compliance audit under 2 CFR 200 Subpart F, please provide a copy of your most recent 2 CFR 200 Subpart F audit report. Anticipated Completion Date: We will submit the questionnaire to all subgrantees during the month of June 2024 and then perform it annually. Responsible Officials: Chief Innovation and Operations Officer and Finance Manager.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 479536 2023-001
    Significant Deficiency
  • 479537 2023-001
    Significant Deficiency
  • 479538 2023-001
    Significant Deficiency
  • 479540 2023-001
    Significant Deficiency
  • 479541 2023-002
    Significant Deficiency
  • 479542 2023-001
    Significant Deficiency
  • 479543 2023-001
    Significant Deficiency
  • 479544 2023-002
    Significant Deficiency
  • 479545 2023-001
    Significant Deficiency
  • 1055978 2023-001
    Significant Deficiency
  • 1055979 2023-001
    Significant Deficiency
  • 1055980 2023-001
    Significant Deficiency
  • 1055981 2023-002
    Significant Deficiency
  • 1055982 2023-001
    Significant Deficiency
  • 1055983 2023-002
    Significant Deficiency
  • 1055984 2023-001
    Significant Deficiency
  • 1055985 2023-001
    Significant Deficiency
  • 1055986 2023-002
    Significant Deficiency
  • 1055987 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.705 Trans-National Crime $1.03M
19.345 International Programs to Support Democracy, Human Rights and Labor $412,540
19.703 Criminal Justice Systems $307,955
19.750 Bureau of Western Hemisphere Affairs (wha) Grant Programs (including Energy and Climate Partnership for the Americas) $147,598
98.001 Usaid Foreign Assistance for Programs Overseas $115,000