Finding 485120 (2023-004)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-08-26
Audit: 317904
Organization: Irl Council (FL)

AI Summary

  • Core Issue: Subrecipient contracts lacked required federal language, impacting compliance with 2 CFR 200.331 and 200.332.
  • Impacted Requirements: Missing information in contracts prevents subrecipients from establishing necessary compliance controls and reporting accurately on federal expenditures.
  • Recommended Follow-Up: Review and amend contracts to include required language, ensure appropriate templates are used, and establish processes for monitoring and follow-up on audit findings.

Finding Text

2023-004 SUBRECIPIENT MONITORING U.S. Department of Environmental Protection ALN 66.456 – National Estuary Program Federal Award ID Number: 4T-02D39922 and CE-00D90119 2023 Funding Criteria: 2 CFR 200.303 requires non-federal entities to establish and maintain effective internal controls. The use of subrecipients in achieving the goals of the federal award requires the establishment of controls over the monitoring of subrecipients pursuant to 2 CFR section 200.331 and 200.332. This includes the requirement for the subaward contract to include information such as the federal award identification (Assistance Listing Number (ALN) and name of the federal program), all requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award and any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. Condition: Subrecipient awards did not consistently include the required language including the ALN and the pass-through of Federal award requirements. Additionally, the Council did not have controls in place to obtain and review subrecipient single audit reports as a means to ensure the subrecipients are taking timely and appropriate action on deficiencies, if any, pertaining to the Federal award. Cause: In some cases, the Council used the contract template for a subaward for a state financial assistance program rather than for a Federal award and, as a result, required information and language was missing from the contract. Further, the Council did not update its procedures over subrecipient monitoring to include follow-up of any deficiencies pertaining to the subrecipients’ use of the Federal funding detected through audits, on-site reviews or other means. Effect: Without the required language in the subrecipient contracts, subrecipients may not have the information necessary for them to establish appropriate controls over compliance required by the Federal award and to appropriately identify the Federal award and related expenditures on their Schedule of Expenditures of Federal Awards, if applicable. Additionally, without the monitoring of the results of audits and on-site reviews, the Council may not have sufficient information to evaluate the risks of noncompliance associated with a subrecipient. Questioned Costs: None. Perspective: The Council did perform monitoring activities related to the use of funds by subrecipients; however, not all controls required for subrecipient monitoring to comply with 2 CFR section 200.331 and 200.332 were fully implemented for the fiscal year under audit. Required language was not included in two of the eight subrecipient awards tested. For one of these two contracts, the contract was originally funded with local share and applied to the Federal award only after the grantor modified the award to allow the Council to apply pre-award expenditures to the grant program. Recommendation: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 485115 2023-001
    Material Weakness
  • 485116 2023-002
    Significant Deficiency
  • 485117 2023-003
    Significant Deficiency
  • 485118 2023-003
    Significant Deficiency
  • 485119 2023-004
    Significant Deficiency
  • 1061557 2023-001
    Material Weakness
  • 1061558 2023-002
    Significant Deficiency
  • 1061559 2023-003
    Significant Deficiency
  • 1061560 2023-003
    Significant Deficiency
  • 1061561 2023-004
    Significant Deficiency
  • 1061562 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
66.456 National Estuary Program $832,199