Finding 518871 (2023-004)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2025-01-13

AI Summary

  • Core Issue: Astraea did not complete required risk assessments for all subrecipients, violating its own policy and federal regulations.
  • Impacted Requirements: Failure to evaluate subrecipient risks could lead to inadequate oversight and potential misuse of funds.
  • Recommended Follow-Up: Ensure all subrecipients undergo documented risk assessments and assign monitoring tools based on their risk levels; require financial reports before advancing funds.

Finding Text

Finding 2023-004: Subrecipient Management and Monitoring (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: As stated in 2 CFR 200.331 part (b), all pass-through entities must evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring procedures to prescribe to each individual subrecipient. Condition: Astraea has a subaward policy, which requires a risk assessment form be completed for each potential subrecipient. However, this step was not completed for all of the subrecipients in which Astraea engaged with during the fiscal year. Cause: Astraea did not adhere to its policy in regards to risk assessment procedures. Context: Astraea failed to perform risk assessment procedures. Our audit work in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. The issue is deemed to be systemic. Effect: Astraea could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: Finding 2022-004 Recommendation: We recommend Astraea adhere to its current subaward policy and ensure the risk assessment procedures over all of its subrecipients are performed and documented prior to engagement. Based on these risk assessments, Astraea should assign a risk level to each, and then determine the monitoring tools to apply based on these risk levels. We also recommend Astraea require its subrecipients to submit financial reports demonstrating use of each advance before advancing more funds, to ensure subrecipients are expending funds appropriately.

Corrective Action Plan

Views of Responsible Officials: Over the past two (2) years, the organization has increased the skill set and capacity among teams for risk assessment and awards management. Subaward policies have been reviewed and all subaward recipients are required to complete pre-award surveys (which include the risk assessment unless the subrecipients are pre-approved by USAID and exempted from such policies). The Associate Director of Grants and Compliance continues to work with members of the Program team to monitor all subrecipient awards for full compliance with 2 CFR 200.516(a).After the FY2022 findings, Astraea sought documentation from Federal agencies where risk assessment exemptions applied. The inception for some of these subawards predated FY2022 and for these, new retroactive risk assessments will be performed.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 518870 2023-003
    Material Weakness Repeat
  • 518872 2023-005
    Material Weakness Repeat
  • 1095312 2023-003
    Material Weakness Repeat
  • 1095313 2023-004
    Material Weakness Repeat
  • 1095314 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $2.51M
19.345 International Programs to Support Democracy, Human Rights and Labor $128,615