Finding Text
Finding 2024-002 Material Weakness: Subrecipient Monitoring – Compliance and Control Finding
ALN 21.027: COVID-19: Coronavirus State and Local Fiscal Recovery Funds
Federal Agency: U.S. Department of the Treasury
Pass-through Entity: Illinois State Board of Education
Criteria Or Specific Requirement: 2 CFR 200.332(a)(1) mandates that the Project inform subrecipients of specific federal award identifiers, including the award date, period of performance, federal awarding agency, Assistance Listing Number, and program name. Furthermore, 2 CFR 200.332(d) requires the Project to review subrecipient financial and performance reports, including single audit reports. Accurate award information allows subrecipients to fulfill their reporting obligations correctly and ensures that federal funds are used appropriately and for the intended purposes.
Condition: The audit revealed that management did not provide subrecipients with accurate award information in all instances. Additionally, the review of subrecipient single audit reports was not included in the Project's established monitoring procedures.
Cause: Management does not have an internal control process in place to ensure proper subrecipient monitoring.
Effect: Failure to communicate all required federal award identifiers to subrecipients may result in their non-compliance with the federal program requirements.
Questioned Costs: None
Context: A review of a sample of 8 subrecipient awards and correspondence revealed that one subrecipient submitted a filing to the Federal Audit Clearinghouse with an incorrect Assistance Listing Number recorded on their data collection form. Additionally, all 16 subrecipients received grant agreements with an incorrect Assistance Listing Number.
Identification As A Repeat Finding: 2023-003
Recommendation: We recommend that all subrecipient grant agreements are updated to include appropriate grant information set forth by 2 CFR 200.332(a)(1) and 2 CFR 200.332(d).
Views Of Responsible Officials And Planned Corrective Action: An adequate subrecipient risk assessment policy will be put in place to evaluate and monitor subrecipients. Southwest Organizing Project will provide subrecipients with all required Federal awards identifiers. Edith Robles will ensure that Federal award identifiers are included in subrecipients' Grant Agreements.