Finding 547170 (2024-002)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-03-31

AI Summary

  • Core Issue: AUW Support Foundation has not documented risk assessments for subrecipients, violating 2 CFR 200.332(b).
  • Impacted Requirements: Lack of risk assessments increases the risk of unallowable costs going undetected, undermining compliance with federal regulations.
  • Recommended Follow-Up: Implement procedures to ensure proper documentation of subrecipient risk assessments and monitoring as required by Uniform Guidance.

Finding Text

Finding 2024-002: Subrecipient Monitoring - Risk Assessment Agency and award: U.S. Department of State - Education and Leadership Development for Young Afghan Women: CFDA No. 19.801 Questioned costs: None. Criteria: In accordance with 2 CFR 200.332(b), Asian University for Women (AUW) Support Foundation should 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 (e) of this section, which may include consideration of such factors as: (1) the subrecipient’s prior experience with the same or similar subawards; (2) the results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F—Audit Requirements of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) whether the subrecipient has new personnel or new or substantially changed systems; and (4) the extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency). Condition: During the audit, we noted that Asian University for Women (AUW) Support Foundation has not documented its evaluation of the subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward. Subrecipient risk assessments are not being performed and the frequency and magnitude of monitoring procedures are not determined based on results of these risk assessments as required by Uniform Guidance 2 CFR 200. Context: Our testing of subrecipient grants awarded found no evidence that risk assessment had been performed. Cause: No risk assessment policies established with the requirements under the Uniform Guidance in accordance with 2 CFR 200.332(b). Effect: Absence of well-documented risk assessment and monitoring plans related to subrecipients may increase the risk of unallowable costs are claimed by the subrecipients and are not prevented or detected by internal controls. Recommendation: We recommend that the management implement procedures to comply with the Uniform Guidance’s requirements related to the documentation of subrecipients’ risk assessment and monitoring procedures. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan

Corrective Action Plan

Finding 2024-002: Subrecipient Monitoring – Risk Assessment Contact: Damaris Johnson Title: Controller Phone number: 617-914-0500 Estimated Completion Date: December 31, 2025 Correct Action Plan: Management does not agree that there is a material weakness related to compliance with the grant. Management would like to note the following points: 1) There are two organizations, The Asian University for Woman (AUW), and the Asian University for Woman Support Foundation (AUWSF). These are separate organizations, but AUWSF exists solely to support AUW, and AUWSF is constantly monitoring AUW. 2) The US State Department has emailed that AUW is NOT a subrecipient of AUWSF. This email was forwarded to the auditors. 3) The US State Department has been substantially involved in helping AUWSF carry out this grant work, since 2022, and has not provided any feedback that the AUWSF should be carrying out additional risk assessment procedures on AUW. 4) AUWSF had a fiscal year 2023 single audit, done by the same auditors here, with substantially the same grants and there was no material weakness related to compliance noted during that audit. 5) A variety of information about the AUW and AUWSF including their clean audited financial statements, internal control policies, and other information is documented and publicly available on the AUW and AUWSF’s joint website. 6) AUWSF notes that it actively monitors and reviews the expenditures of the funds they provide to AUW. The funds are paid in installments and only upon satisfactory receipt of documentation of funds expended are subsequent installments sent. AUWSF receives monthly financial statements and bank statements from AUW to further reconfirm the AUW expenditures. Nonetheless, AUWSF takes any potential significant deficiency in internal control very seriously and will seek guidance from the US State Department to clarify this item and implement any necessary changes.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 547171 2024-003
    Material Weakness
  • 547172 2024-004
    Material Weakness
  • 1123612 2024-002
    Material Weakness
  • 1123613 2024-003
    Material Weakness
  • 1123614 2024-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
19.801 Office of Global Women's Issues $2.14M
19.345 International Programs to Support Democracy, Human Rights and Labor $300,000