Finding 522783 (2023-009)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2023
Accepted
2025-02-12
Audit: 342154
Organization: City of Flint (MI)

AI Summary

  • Core Issue: The City failed to include required information in subaward contracts, such as the federal program name and assistance listing number, and did not document risk assessments for subrecipients.
  • Impacted Requirements: Compliance with the Uniform Guidance is compromised, increasing the risk of future noncompliance due to inadequate internal controls.
  • Recommended Follow-Up: Implement internal controls and grant management software to ensure compliance documentation is maintained and requirements are met.

Finding Text

2023-009 – Subrecipient Monitoring Finding Type. Immaterial Noncompliance/Sigificant Deficiency in Internal Control over Compliance (Subrecipient Monitoring). Program. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01. Criteria. When a grant recipient makes subawards to other recipients, certain compliance requirements are required in order to monitor the activity of the subrecipients. The Uniform Guidance requires that the pass-through entity 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 200.331(a)(1); (2) all requirements imposed by the Pass-Through Entity (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 200.331(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 200.331(a)(3)). The Uniform Guidance further requires that the pass-through entity valuate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward (2 CFR section 200.331(b)). This evaluation of risk may include consideration of such factors as: (1) The subrecipient’s prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives single audit in accordance with 2 CFR part 200, subpart F, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of federal awarding agency monitoring (e.g., if the subrecipient also receives federal awards directly from a federal awarding agency). Condition. Subaward contracts review did not contain appropriate information related to the federal program. No assistance listing number or federal program name was noted in the language of the agreements. In addition, no evidence of formal risk assessment was documented. Cause. The City does not have the proper internal controls in place to ensure that contract language contains all of the information required to be communicated under the Uniform Guidance or that documentation of the risk assessment process related to subrecipients of federal awards is maintained. Effect. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls. Questioned Costs. No costs were required to be questioned as a result of this finding inasmuch as our testing of the monitoring process and tests of transactions did not indicate any unallowable costs. Recommendation. We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained. View of Responsible Officials. The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented. Part of the solution will be implementing grant management software.

Corrective Action Plan

2023-009 – Subrecipient Monitoring Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Subrecipient Monitoring). Program. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01. Auditor Description of Condition and Effect: Subaward contracts review did not contain appropriate information related to the federal program. No assistance listing number or federal program name was noted in the language of the agreements. In addition, no evidence of formal risk assessment was documented. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls. Auditor Recommendation: We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained. Corrective Action: The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented. Part of the solution will be implementing grant management software. Responsible Person: Phillip Moore, Chief Financial Officer Anticipated Completion Date: January 21, 2025

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $13.57M
66.458 Clean Water State Revolving Fund $10.78M
14.889 Choice Neighborhoods Implementation Grants $2.66M
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $851,204
11.307 Economic Adjustment Assistance $733,317
59.077 Community Navigator Pilot Program $434,085
14.218 Community Development Block Grants/entitlement Grants $348,860
14.231 Emergency Solutions Grant Program $308,013
16.833 National Sexual Assault Kit Initiative $282,433
66.468 Drinking Water State Revolving Fund $161,805
14.900 Lead Hazard Reduction Grant Program $153,669
16.045 Community-Based Violence Intervention and Prevention Initiative $65,587
93.197 Childhood Lead Poisoning Prevention Projects, State and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $17,260
16.738 Edward Byrne Memorial Justice Assistance Grant Program $15,542
14.239 Home Investment Partnerships Program $9,505
16.034 Coronavirus Emergency Supplemental Funding Program $3,125
32.011 Affordable Connectivity Outreach Grant Program $2,183