Finding Text
Finding 2023-012 – Lack of Internal Controls and Noncompliance with Subrecipient Monitoring Over Federal Grant – Coronavirus State and Local Fiscal Recovery Funds
PASS-THROUGH GRANTOR: Direct Grant
FEDERAL AGENCY: U.S. Department of Treasury
ASSISTANCE LISTING: 21.027
FEDERAL PROGRAM NAME: Coronavirus State and Local Fiscal Recovery Funds
FEDERAL AWARD YEAR: 2021
CONTROL CATEGORY: Subrecipient Monitoring
QUESTIONED COSTS: $-0-
Condition: The County does not have a subrecipient monitoring policy, and not all subrecipient agreements comprised of the following information:
• Subrecipient Authorized Representative and program contact information
• Subrecipient Employee Identification Number (EIN) and DUNS number
• Federal Award Identification Number (FAIN)
• Name of Federal Awarding Agency
• Contact information for the official at the Federal Awarding Agency
• Catalog of Assistance Listing (AL) number and name
• Federal award date
• Provide close out terms and conditions
Further, subrecipient and beneficiary agreements approved by the Board of County Commissioners state that subrecipient or beneficiary shall provide monthly performance reports until all Coronavirus State and Local Fiscal Recovery Funds awarded hereunder have been expended. Through the observation of records, it was determined that monthly performance reports were not submitted each month by entities receiving Coronavirus State and Local Fiscal Recovery Funds.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with compliance requirements.
Effect of Condition: This condition resulted in noncompliance with Federal grant requirements.
Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements. OSAI also recommends that entities receiving ARPA funding submit monthly progress reports as stated under the reporting section of the agreements signed by the Board of County Commissioners.
Management Response:
Chairman of the Board of County Commissioners: The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.
Criteria: 2 CFR § 200.332 Requirements for Pass-Through Entities states in part:
All pass-through entities must:
(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward.
(2) 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.
(5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part.
(6) Appropriate terms and conditions concerning closeout of the subaward.