Finding 537455 (2024-001)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-03-26
Audit: 348663
Organization: Brac Usa, Inc. (NY)

AI Summary

  • Core Issue: The entity lacks formal procedures to verify if subrecipients have completed required audits, risking noncompliance with federal regulations.
  • Impacted Requirements: Compliance with 2 CFR § 200.332(f) and § 200.501, which mandate that subrecipients receiving over $750,000 undergo audits and that pass-through entities monitor compliance.
  • Recommended Follow-Up: Develop written procedures for identifying subrecipients, requiring annual audit submissions, reviewing audit reports, and documenting compliance actions.

Finding Text

Finding 2024 - 001 Lack of Subrecipient Monitoring Procedures – Verification of Audits Information on the Federal Programs: 19.511 Criteria: Per 2 CFR § 200.332(f), pass-through entities must ensure that subrecipients expending $750,000 or more in Federal awards during the subrecipient’s fiscal year undergo a single or program-specific audit as required by 2 CFR § 200.501. Additionally, per 2 CFR § 200.332(d), passthrough entities must monitor subrecipients to ensure compliance with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: During the audit, it was noted that the entity does not have a formalized process in place to verify whether subrecipients required to undergo a single audit have completed and submitted the audit as required. Specifically, there was no documented evidence that the entity reviewed audit reports or followed up on subrecipient audit compliance. Cause: The entity has not established or implemented adequate policies and procedures to monitor subrecipient compliance with audit requirements under the Uniform Guidance. Effect or Potential Effect: Failure to verify and review subrecipient audit reports increases the risk that noncompliance, questioned costs, or internal control deficiencies at the subrecipient level go undetected, potentially resulting in unallowable costs or noncompliance with Federal regulations. Questioned Costs: None noted at this time; however, the lack of monitoring increases the risk of unallowable costs in Federal programs. Context: BRAC USA has one primary subrecipient for which a single audit was not performed prior to our audit fieldwork. Identification as a Repeat Finding, if Applicable: Not a repeat finding. Recommendation: We recommend that the entity develop and implement formal written procedures to ensure subrecipient audit requirements are met. These procedures should include:  Identifying subrecipients required to undergo a single audit.  Requiring subrecipients to submit audit reports and management letters annually.  Reviewing subrecipient audit reports to identify findings that may impact the entity.  Establishing follow-up procedures to address and resolve subrecipient audit findings.  Maintaining documentation of audit verification and any corrective actions taken.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Actions: We are committed to strengthening our internal controls and procedures to ensure full compliance with Uniform Guidance requirements. We also acknowledge that the audit waiver BRAC Bangladesh received from the USAID Mission in Bangladesh was not sufficient to exempt them from conducting a program-specific audit of the Department of State (BPRM) funded project, SPRMCO23CA0152. In response to the finding, BRAC Bangladesh has already conducted an audit of the project, which demonstrated that the financial statements and schedule of expenditures were free from material misstatements. Moving forward, we will amend our subagreement templates to include specific language around USG audit requirements, and the submission of audit reports will be included in the reporting section of the agreements. We will also update our Fiscal Policies and Procedures Manual to formalize the process for receiving and reviewing audit reports, and establishing follow-up procedures to resolve potential audit findings. We will also maintain clear documentation of the submission, review, and follow up of audits.

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles

Other Findings in this Audit

  • 1113897 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.511 Overseas Refugee Assistance Programs for East Asia $1.39M
98.001 Usaid Foreign Assistance for Programs Overseas $612,025