Finding 511929 (2023-001)

Program Information: 84.287C Twenty-First Century Community Learning Centers; Lottery for Education: Afterschool Programs (LEAP) Criteria: (CFR) Section 200.332 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 200.332(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 200.332(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 200.332(a)(3)). Condition: The Organization did not execute awards with its subrecipients until after funds were disbursed to the subrecipient. Cause: Lack of administrative oversight with respect to subrecipient monitoring requirements. Effect: The Organization was not in compliance with subrecipient monitoring requirements. Questioned Costs: None Context: The Organization did not execute awards with its subrecipients until April 2024. Identification as a Repeat Finding: No similar findings noted in the prior year. Recommendation: We recommend that the Organization enhance its policies and procedures over subrecipient monitoring to ensure subaward agreements are executed at the time of the subaward. Views of Responsible Officials: The Alliance will implement additional administrative oversight to execute subaward agreements in a timely manner.