Finding 548626 (2024-002)

Subrecipient Monitoring (Significant Deficiency in Internal Controls over Compliance, Other Noncompliance) Federal agency – U.S. Department of Health and Human Services Federal program title – Foster Care – Title IV-E Assistance listing number – 93.658 Criteria – 2 CFR Part 200 Uniform Administrative Requirements, Post Federal Award Requirements and Cost Principles for Federal Award (Uniform Guidance) requires the grantee to monitor the activities of subrecipients to ensure the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and terms and conditions of the subaward. Additionally, when the County passes money through to subrecipients, the County must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information at the time of the subaward.Condition and Context – During our testing, we selected 6 subrecipients from a population of 27 subrecipients for testing and the County was unable to provide us with documentation of their risk assessment and the County did not document their review of the single audit reports of the subrecipients as part of their monitoring procedures for all 6. Management does review the California Department of Social Services management decision letters and facility evaluation report on the California Department of Social Services website, but does not document their review. Questioned costs – None Cause – The County does not have the proper training regarding compliance Uniform Guidance for subrecipients. Effect – The County was not in compliance with federal award subrecipient monitoring requirements. Continued noncompliance could result in sanctions by the federal awarding agency, including withholding future funding. Repeat finding – Yes, prior year 2023-002 Recommendation – The County should establish policies and procedures to ensure risk assessment is documented. The County should also obtain the single audit reports for their subrecipients and issue management decision letters as part of their monitoring. Views of responsible officials – The County (Human Services Agency) acknowledges that, at the time of the FY 2023/24 audit, there was no documented process for completing risk assessments, obtaining copies of single audit reports for each FFA, group home, and STRTP subrecipient, or issuing management decision letters as part of a documented monitoring policy and procedure. The County (Human Services Agency) relies on CDSS to perform certain licensing and oversight functions as the single state agency for Title IV-E funds. The County (Human Services Agency) is responsible for and does review these audits and their findings. In response to this finding, the County (Human Services Agency) has established a documented process, implemented in FY 2024/25 documenting risk assessments, obtaining copies of the single audit reports for each FFA, group homes, and STRTPs subrecipient, and issuing management decision letters to ensure compliance.