Finding Text
Information on the federal program:
Federal Agency: Department of the Treasury
Pass-Through Entity: N/A – Direct Grant
Federal Program: Coronavirus State and Local Fiscal Recovery Funds (CSLFRF)
Assistance Listing Number: 21.027
Compliance Requirement: Subrecipient Monitoring
Audit Findings: Material Weakness, Noncompliance
Criteria: Title 2 Subtitle A Chapter II Part 200 Subparts A and D, Section 200.332, establishes requirements
that pass-through entities must adhere to their subrecipient grant agreements and the monitoring processes
of those subrecipients.
Condition: City of Bloomington was unable to identify subrecipients of CSLFRF funding for the purposes
of financial reporting and compliance with requirements under 2 CFR 200.332. Management misreported
subrecipient activity on the SEFA, failed to include required contractual language for subrecipient awards
in executed agreements, and did not perform monitoring procedures over the subrecipients that were
identified during testing procedures.
Cause: The City does not have an effective system of internal controls in place to effectively structure and
review CSLFRF subaward agreements or to effectively monitor subrecipients.
Effect: Due to lack of required information being present with agreements and the contracts not clearly
differentiating between a subrecipient and a beneficiary, there could be noncompliance issues in how funds
are spent and recorded by the subrecipient, which could lead to noncompliance issues for the City of
Bloomington and its subrecipients.
Questioned costs: There are no questioned costs.
Context: The 10 subrecipients represent approximately 38%, $1,935,000, of the total award expenditures
of $4,999,384. The condition reported was prevalent for each subrecipient participating in the award.
Identification as a repeat finding, if applicable: This is not a repeat finding. Recommendation: We recommend that the City institute a policy for the handling of subrecipients for all
sources of federal funding. The City should review Title 2 Subtitle A Chapter II Part 200 Subpart A and
ensure their agreements with subrecipients include all required information. Management should review
Title 2 Subtitle A Chapter II Part 200 Subpart D and ensure all necessary monitoring procedures are being
performed over subrecipients moving forward.
Views of responsible officials and planned corrective actions: Management acknowledges the
finding. See management’s corrective action plan attached to this audit report.