Finding 537541 (2024-003)

INSTANCE OF NONCOMPLIANCE 2024-003 COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Subrecipient Monitoring Condition: The Agency did not identify the subaward of the Coronavirus State and Local Fiscal Recovery Funds and applicable requirements at the time the subaward was made. Because of the failure to identify the subaward, the Agency was not able to comply with monitoring subrecipient activities to provide reasonable assurance that the subrecipient administered the subaward in compliance with the terms and conditions of the subaward in accordance with the Uniform Guidance. Criteria: Federal administration requires a pass-through entity (PTE) to identify the federal award and requirements to a subrecipient and to then monitor subrecipient activities. Cause: Since the Agency did not identify the subaward at time of contract, they did not complete subrecipient compliance requirements as required under the Uniform Guidance throughout the grant period. Effect: The Agency did not notify the subaward as identified in finding 2024-002, and therefore, was not following subrecipient monitoring requirements under the Uniform Guidance and the costs could potentially be disallowed. Recommendation: We recommend that any subrecipients are identified at time contracts are agreed upon and that the Agency ensures proper subrecipient notification and monitoring throughout the grant period for compliance with the Uniform Guidance.