Finding Text
NATIONAL SCIENCE FOUNDATION
Program Information
Assistance Listing # 47.076 STEM Education
2023-001 Documentation of Subawards
Material Weakness
Criteria: The Code of Federal Regulations (CFR) Section 200.331 requires a pass-through entity (PTE) to clearly identify to the subrecipient: (1) the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); (2) all requirements imposed by the PTE on the subrecipient so that the federal award is used in accordance with federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and (3) any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)).
Condition: A sample of three subawards were selected. Two of the three subawards did not have a subaward agreement.
Cause: This is the first year that the Foundation was required to have a Single audit and as such is still in the process of developing and adopting specific policies for sub-awards and subrecipients.
Effect: During 2023 contemporaneous documentation was not obtained from sub-awardees and sub-recipients.
Auditor’s Recommendation: We recommend that management require all sub-awardees to have a subaward agreement or memorandum of understanding (MOU).
Views of Responsible Officials and Planned Corrective Actions: The Foundation’s management team agrees with this finding and remains fully committed to both developing and adopting specific policies for sub-awards and sub-recipients which will better ensure its internal practices are in alignment with the Uniform Guidance.