FAC Explorer

Finding 514169 (2023-004)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2024-12-13
Audit: 332366
Organization: Pueblo County Colorado (CO)
Auditor: Cliftonlarsonallen LLP

AI Summary

  • Core Issue: Subrecipients did not receive all required information in their agreements, including critical identifiers like the CFDA number and FAIN.
  • Impacted Requirements: Non-compliance with 2 CFR 200.331 and 200.332 regarding risk evaluation and monitoring of subrecipients.
  • Recommended Follow-up: Review and enhance procedures to ensure all required information is included in subaward documents and establish effective monitoring practices.

Finding Text

Criteria or specific requirement: Per 2 CFR 200.331(a) states that all pass-through entities must 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. Required information includes, federal award identification, subrecipient name, subrecipient’s DUNS number, federal award identification number (FAIN), federal award date, subaward start and end date, amount of federal funds obligated, total amount of federal award, federal award project description, name of federal awarding agency, Assistance Listing (CFDA) number and name, identification of whether the award is R&D and indirect cost rate for federal award. Per 2 CFR 200.303, requires that non-federal entities receiving federal awards establish and maintain internal control designed to reasonably ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. Effective internal control should include procedures to ensure required information is communicated prior to the issuance of the subaward. Per 2 CFR 200.331(a)(1), pass-through entities must evaluate each subrecipient’s risk of noncompliance to determine the appropriate level of monitoring of the subrecipient. Per 2 CFR 200.332(d) through (f), pass-through entities must monitor the activities of the subrecipient, which includes reviewing financial reports required by the pass-through entity. Condition: During our testing, we noted subrecipients tested had required information omitted from the sub agreements to the subrecipients including Assistance Listing (CFDA) title and number, subrecipient’s DUNS number, Federal Award Identification Number (FAIN), identification of whether the award is research and development, and indirect cost rate for federal award. Subrecipients tested did not have evidence of the County’s evaluation of the risk of noncompliance by the subrecipients, nor was there evidence of monitoring of annual audits for the subrecipients. Internal checklists that aid in compliance were missing for certain subrecipients. Quarterly reports were also not submitted to the County by the subrecipients subsequent to funding. Questioned costs: None. Context: Five out of the five subrecipients did not include required information in subaward agreements issued to subrecipients and lacked evidence of both the evaluation of risk of noncompliance of the subrecipient and monitoring of annual audits for the subrecipients. One of the five subrecipients was missing an internal checklist that is signed by the County Manager. Five of the five subrecipients were provided the funding at the beginning of the grant award period and no required quarterly reports were submitted to the County subsequent to funding. Cause: Lack of sufficient controls in place to ensure that subrecipient agreements contain all required information and are monitored appropriately. Effect: Failure to communicate required information and to adequately monitor the subrecipients could result in subrecipients not properly administering the federal programs in accordance with federal regulations. Repeat Finding: Yes, repeat of prior year finding 2022-004. Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 514160 2023-001
    Significant Deficiency
  • 514161 2023-001
    Significant Deficiency
  • 514162 2023-002
    Significant Deficiency
  • 514163 2023-002
    Significant Deficiency
  • 514164 2023-003
    Material Weakness Repeat
  • 514165 2023-003
    Material Weakness Repeat
  • 514166 2023-003
    Material Weakness Repeat
  • 514167 2023-004
    Material Weakness Repeat
  • 514168 2023-004
    Material Weakness Repeat
  • 514170 2023-005
    Material Weakness Repeat
  • 514171 2023-005
    Material Weakness Repeat
  • 514172 2023-005
    Material Weakness Repeat
  • 514173 2023-006
    Significant Deficiency
  • 514174 2023-006
    Significant Deficiency
  • 514175 2023-006
    Significant Deficiency
  • 1090602 2023-001
    Significant Deficiency
  • 1090603 2023-001
    Significant Deficiency
  • 1090604 2023-002
    Significant Deficiency
  • 1090605 2023-002
    Significant Deficiency
  • 1090606 2023-003
    Material Weakness Repeat
  • 1090607 2023-003
    Material Weakness Repeat
  • 1090608 2023-003
    Material Weakness Repeat
  • 1090609 2023-004
    Material Weakness Repeat
  • 1090610 2023-004
    Material Weakness Repeat
  • 1090611 2023-004
    Material Weakness Repeat
  • 1090612 2023-005
    Material Weakness Repeat
  • 1090613 2023-005
    Material Weakness Repeat
  • 1090614 2023-005
    Material Weakness Repeat
  • 1090615 2023-006
    Significant Deficiency
  • 1090616 2023-006
    Significant Deficiency
  • 1090617 2023-006
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.558 Temporary Assistance to Needy Families $9.55M
93.568 Low-Income Home Energy Assistance (dss) $5.23M
93.778 Title Xix, Medicaid Medical Assistance Program $3.31M
93.658 Foster Care - Title IV-E $3.26M
93.575 Child Care and Development Block Grant $2.89M
10.569 Emergency Food Assistance Program (food Commodities Non-Cash) $2.32M
93.563 Title IV-D, Child Support Enforcement $2.24M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $2.02M
97.040 Chemical Stockpile Emergency Preparedness $1.75M
93.778 Single Entry Point, Medical Assistance Program $1.58M
93.659 Adoption Assistance $1.29M
81.042 Weatherization Assistance for Low-Income Persons $1.10M
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $904,422
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $773,865
10.565 Commodity Supplemental Food Program (commodities - Non-Cash) $633,791
93.667 Social Services Block Grant - Title Xx $599,114
93.044 Title Iii, Part B - Grants for Supportive Services and Senior Centers $588,125
93.045 Title Iii, Part C - Nutrition Services $571,954
93.568 Low-Income Home Energy Assistance (hhs) $448,240
23.032 Local Assistance and Tribal Consistency Fund $406,623
97.036 Disaster Grants - Public Assistance $364,703
97.067 Homeland Security Grant $355,160
14.231 Emergency Solutions Grant Program $320,446
93.569 Community Services Block Grant $306,617
93.959 Substance Abuse Prevention and Treatment Block Grant $238,170
16.738 Edward Byrne Memorial Justice Assistance Grant Program $156,726
93.090 Guardianship Assistance $145,135
93.645 Child Welfare Services-State Grants Title IV-B $142,686
10.565 Commodity Supplemental Food Program (admin) $119,834
93.958 Block Grant for Community Mental Health Services $95,171
97.042 Emergency Management Performance Grant $92,075
16.575 Crime Victim Assistance (sheriff) $79,057
93.053 Nutrition Services Incentive Program (usda) $72,072
93.674 Chafee Foster Care Independence Program $60,703
16.606 State Criminal Alien Assistance Program $50,682
20.616 National Priority Safety Programs $46,914
14.218 Community Development Block Grants $45,678
93.634 Applied Research in Child Welfare (arch) $34,061
16.575 Crime Victim Assistance (da) $30,096
93.052 Title Iii, Part E - National Family Caregiver Support $28,414
93.041 Title Vii - Chapter 3 - Programs for Prevention of Elder Abuse, Neglect, and Exploitation $28,129
93.747 Covid-19 - Elder Abuse Prevention Interventions Program $17,087
16.922 Federal Forfeiture Funds $13,010
10.569 Emergency Food Assistance Program (admin) $10,000
93.043 Title Iii, Part D - Disease Prevention and Health Promotion Services $9,242
93.592 Family Violence Prevention and Services/discretionary $5,906