Finding 529424 (2024-004)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-03-23
Audit: 347428
Organization: Catholic Social Services, Inc. (AK)
Auditor: Moss Adams LLP

AI Summary

  • Core Issue: CSS failed to monitor one of its subrecipients, risking undetected issues with grant compliance.
  • Impacted Requirements: Federal regulations require pass-through entities to ensure subrecipients comply with all terms and conditions of the subaward.
  • Recommended Follow-up: Revise monitoring procedures to include all subrecipients and ensure audit reports are obtained and reviewed for compliance.

Finding Text

Criteria or specific requirement – A non-federal entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statues, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. In monitoring a subrecipient, a pass-through entity must review financial and performance reports; ensure that the subrecipient takes corrective action on all significant developments that negatively affect the subaward such as single audit findings related to the subaward, issue a management decision for audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity, and resolve audit findings specifically related to the subaward. Condition – For one of the subrecipients selected for testing, CSS noted that monitoring is not completed. Context – Of the eight subrecipients that received pass-through funding from CSS, we randomly selected three for testing. Our random sample was not, nor intended to be, statistically valid. One of the three subrecipients was not monitored appropriately. Effect – The subrecipient may have findings related to the grant funding provided by CSS which were unknown and not adequately addressed by CSS. Cause – CSS did not have the appropriate controls in place over the subrecipient monitoring process. Repeat finding – No. Recommendation – We recommend CSS revise their procedures to include all subrecipients in their monitoring procedures, obtaining audit reports for all subrecipients to ensure there are no audit findings related to the subaward and issue management decisions for any audit findings that are identified. Views of Responsible Officials – Management agrees with the finding and recommendation.

Corrective Action Plan

One subrecipient was not monitored appropriately, increasing the risk of noncompliance with grant requirements. Corrective Actions: 1. Standardized Subrecipient Monitoring Procedures: o Develop a formal subrecipient monitoring policy to ensure all subrecipients are reviewed. o Target Completion: Policy finalized within the end of Fiscal Year 2025. 2. Require Annual Audit Reports from All Subrecipients: o CSS will require all subrecipients to submit annual audit reports to identify any compliance risks. o Target Completion: First audit report request within next fiscal quarter. 3. Designated Subrecipient Compliance Director: o Assign a compliance director within the State Refugee Designee team at CSS to oversee and track subrecipient monitoring, ensuring all required reviews are conducted. o Target Completion: Role assigned within the end of Fiscal Year 2025. Responsible Staff: State Refugee Coordinator in conjunction with Senior Director of Grants and Chief Financial Officer

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 529422 2024-002
    Material Weakness
  • 529423 2024-003
    Material Weakness
  • 1105864 2024-002
    Material Weakness
  • 1105865 2024-003
    Material Weakness
  • 1105866 2024-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $4.08M
64.033 Va Supportive Services for Veteran Families Program $1.16M
21.027 Coronavirus State and Local Fiscal Recovery Funds $895,557
14.218 Community Development Block Grants/entitlement Grants $726,810
21.023 Emergency Rental Assistance Program $541,419
93.576 Refugee and Entrant Assistance Discretionary Grants $535,259
19.510 U.s. Refugee Admissions Program $367,850
21.019 Coronavirus Relief Fund $275,947
93.583 Refugee and Entrant Assistance Wilson/fish Program $239,231
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $209,424
10.935 Urban Agriculture and Innovative Production $169,290
64.024 Va Homeless Providers Grant and Per Diem Program $58,519
97.024 Emergency Food and Shelter National Board Program $27,524