Finding 512189 (2024-003)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2024-11-26

AI Summary

  • Core Issue: There is a significant deficiency in internal controls regarding compliance with subaward identification requirements.
  • Impacted Requirements: Subawards must clearly include the Assistance Listing Number, Federal agency name, and identification as a subaward per Title 2, Part 200, Subpart D.
  • Recommended Follow-Up: Review and update subaward templates to ensure they meet all Uniform Guidance requirements.

Finding Text

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Special Programs for the Aging – Title III Part C Nutrition Services Assistance Listing Number: 93.045 Pass-Through Agency: Trellis Area Agency on Aging Pass-Through Number(s): 311-23-003C-118-001, 311-24-003C-118-001 Award Period: 2023 and 2024 Type of Finding: * Significant Deficiency in Internal Control over Compliance * Other Matters Criteria or specific requirement: Title 2, Part 200, Subpart D, 200.332(b)(1) requires that subawards must be clearly identified to the subrecipient and include various information, including the Assistance Listing Number (ALN), Federal agency name, and clear identification of the subaward. Condition: For the three subawards viewed, the Assistance Listing Number, Federal agency name, and subaward identification was not included. Context: Other required information, including the subrecipient name, UEI number, budget period, and funding requirements, were noted in the agreement. However, the agreement was not clearly identified as being a subaward (referred to as a contractor), and the Federal agency name and ALN were not included. Cause: The subaward template used did not include the required components. Effect: Subrecipients may not be aware of the requirements of the federal funding. Recommendation: We recommend careful review of the Uniform Guidance requirements for subaward contracts in comparison to subaward agreement templates to identify requirements and updates needed. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Special Programs for the Aging – Title III Part C Nutrition Services – Assistance Listing No. 93.045 Recommendation: We recommend careful review of the Uniform Guidance requirements for subaward contracts in comparison to subaward agreement templates to identify requirements and updates needed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization has worked closely with Trellis, the Area Agency on Aging, to review the Uniform Guidance requirements for subaward contracts. Together, they will update the Senior Nutrition Program Purchase of Service Contracts for 2025 to ensure compliance. The updated contracts will now include the required Federal Award Identification Number (FAIN) and the Catalog of Federal Domestic Assistance (CFDA) number for Assisted Living programs. These actions will address the recommendations and ensure alignment with the Uniform Guidance requirements.. Name of the contact person responsible for corrective action: Linda Kirkendall, Associate Director of the organization’s Senior Nutrition Program Planned completion date for corrective action plan: January 1, 2025

Categories

Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 1088631 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.045 Special Programs for the Aging, Title Iii, Part C, Nutrition Services $735,011
94.002 Americorps Seniors Retired and Senior Volunteer Program (rsvp) 94.002 $435,122
14.235 Supportive Housing Program - Our Home Capital Supportive Housing $121,527
93.044 Special Programs for the Aging, Title Iii, Part B, Grants for Supportive Services and Senior Centers $77,635
10.555 National School Lunch Program $56,456
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $50,374
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $23,877
10.553 School Breakfast Program $3,410