Finding Text
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.332, which established
requirements over subawards for pass-through entities and states, in part:
All pass-through entities must:
a) Verify that the subrecipient is not excluded or disqualified in accordance with § 180.300. Verification methods
are provided in § 180.300, which include confirming in SAM.gov that a potential subrecipient is not suspended,
debarred, or otherwise excluded from receiving Federal funds.
b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following
information at the time of the subaward and if any of these data elements change, include the changes in
subsequent subaward modification. When some of this information is not available, the pass-through entity
must provide the best information available to describe the Federal award and subaward. Required information
includes:
1. Federal award identification.
i. Subrecipient name (which must match the name associated with its unique entity identifier);
ii. Subrecipient's unique entity identifier;
iii. Federal Award Identification Number (FAIN);
iv. Federal Award Date (see the definition of Federal award date in §200.1 of this part) of award to the
recipient by the Federal agency;
v. Subaward Period of Performance Start and End Date;
vi. Subaward Budget Period Start and End Date;
vii. Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient;
viii. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including
the current financial obligation;
ix. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
x. Federal award project description, as required to be responsive to the Federal Funding
Accountability and Transparency Act (FFATA);
xi. Name of Federal awarding agency, pass-through entity, and contact information for awarding
official of the Pass-through entity;
xii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made
available under each Federal award and the Assistance Listings Number at time of disbursement;
xiii. Identification of whether the award is R&D; and
xiv. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per §200.414.
c) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and
conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in
paragraph (f) of this section;
d) If appropriate, consider implementing specific conditions in a subaward as described in § 200.208 and notify the
Federal agency of the specific conditions.
e) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized
purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and
that subaward performance goals are achieved;
f) Depending upon the pass-through entity's assessment of risk posed by the subrecipient (as described in
paragraph (c) of this section), the CFR lists monitoring tools that may be useful for the pass-through entity to
ensure proper accountability and compliance with program requirements and achievement of performance
goals.
We noted the District did not perform a subrecipient checklist prior to allocating funds. Additionally, the District did
not complete monitoring procedures for subrecipients. Further, we noted the District signed a service agreement
with the subrecipient; however, the agreement did not specifically identify the subrecipient as a subrecipient or
include all award information as required above. Per inquiry of the Treasurer, the District does not review audit
reports of the subrecipient for any noted deficiencies. The District should implement procedures to verify that all
required reviews and any additional required follow ups are completed and accurately documented. Further, the
District should ensure all required information is included in the subrecipient agreement. We recommend that the
District request copies of annual audit reports of the subrecipient to review the report for any potential deficiencies.