Finding Text
2023-002: Subrecipient Monitoring - Significant Deficiency Internal Control and Compliance
Repeat of Prior Audit Finding 2022-005
Federal Program: Trans-National Crime
Federal Agency: U.S. Department of State - Bureau of International Narcotics and Law Enforcement Affairs
Federal Assistance Listing Number: 19.705
Federal Award Year: December 31, 2023
Criteria: 2 CFR section 200.303(a) of the Uniform Guidance requires all non-Federal entities to establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-Federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and conditions of the Federal awards. In addition, 2 CFR section 200.332 requires pass-through entities to monitor the subrecipient, including verifying that every subrecipient is audited as required by the Uniform Guidance when it is expected that the subrecipient's federal expenditures exceed the threshold.
Condition/Context: For the selection of 2 subrecipients, the Corporation did not inquire of the subrecipients to confirm their applicability of an annual Uniform Guidance audit, nor does the Corporation request a copy of the Uniform Guidance audit report to be provided, when applicable.
This was not a statistically valid sample.
Questioned Costs: Not determinable.
Cause: The Corporation's procedures did not include this process as part of its policies and procedures. As a result, the Corporation did not request for an affirmation or a copy of the Uniform Guidance audit to be provided. Consequently, the Corporation did not verify whether the Uniform Guidance audit was applicable to any of its subrecipients.
Effect: The Corporation's control design and operation does not provide reasonable assurance that the Corporation is managing the subrecipient monitoring requirements of the Uniform Guidance.
Recommendation: We recommend that the Corporation appropriately monitor its subrecipients to ensure that they are being audited in accordance with the Uniform Guidance, when applicable. In the event that such subrecipients do not require a Uniform Guidance audit, the Corporation should obtain and retain supporting documentation such as an affirmation letter from the subrecipients. When a subrecipient is subject to the Uniform Guidance audit, the Corporation should obtain a copy of the related audit report and perform a review of such audit report and note any potential findings that could pertain to the funding that the Corporation provided to such subrecipient. In addition, the Corporation should consider checking the Federal Audit Clearinghouse website to verify if its subrecipients submitted the single audit reporting package in the year that the Corporation funded.
View of Responsible Officials: The Corporation will implement a process to obtain single audit affirmation letters from subrecipients annually, if applicable, and confirm as per current understanding and discussions with subrecipients during the due diligence process that their funding from the United States federal government sources during the agreement period will not exceed $750,000 annually. These steps will ensure proper subrecipient monitoring in alignment with federal regulations.