Finding Text
Program: Assistance Listing Number 59.059 – Congressional Earmarks Initiative
Awarding Agency – U.S. Small Business Association
Grant Number – SBAHQ23I0008
Federal Award Year – 2024
Questioned Cost: None.
Criteria: Per 2 CFR 200.332, Central Michigan University Research Corporation is required to
perform risk assessment and monitoring procedures for subrecipients of federal
grants. This includes procedures such as evaluating the subrecipient’s risk of
noncompliance with Federal statutes, regulations, and the terms and conditions of the
subaward, review of financial and performance reports, and follow up of the
subrecipient’s correction of previous Single Audit findings.
Condition: The Organization lacked documentation that sufficient subrecipient risk assessment
and monitoring procedures were performed as required by Uniform Guidance. An
assumption was made that because the subrecipient was to receive funding as part of
a federal mandate that the Organization’s only responsibility was to pass through the
funding.
Cause / Effect: Management does not have the proper policies and procedures in place to ensure that
the required subrecipient procedures are being performed, causing noncompliance.
Recommendation: We recommend that management reviews the required procedures for pass-through
entities as listed in 2 CFR 200.332 and implements the procedures accordingly. This
should include documented risk assessment and monitoring procedures for all
subrecipient of federal awards.
Views of Responsible
Officials: Management agrees with the finding.
Corrective Action Plan: See attached corrective action plan from management.