Finding Text
Criteria
Section 200.303 notes “The non-Federal entity must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.”
Condition
While performing tests of the Garden’s internal controls over compliance, we noted the Garden had contracted with a subrecipient related to the above award. However, the Garden was unable to provide any documentation to support monitoring of the subrecipient, or that the entity was in fact a subrecipient, as opposed to a subcontractor.
Cause of Condition
The Garden has not implemented proper internal control policies to adhere to the requirements of the Uniform Guidance.
Effect of Condition
Noncompliance may impact future funding from Federal awards.
Recommendation
We recommend the Garden implement proper internal control procedures including implementing and following a subrecipient monitoring policy in line with the Uniform Guidance.