Finding Text
NONCOMPLIANCE WITH SUBRECIPIENT MONITORING REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, AL No. 21.027, GRANT No. AM-23-0211
Criteria: Per the 2024 OMB compliance supplement, subrecipient monitoring is required by pass-through entities for all SLFRF funded projects. Among other activities, Treasury considers the following activities to be part of subrecipient monitoring:
• Ensuring that the subrecipient has access to information about public programs relevant to the subrecipient’s duties necessary to ensure that subaward performance goals are achieved.
• Ensuring that the subrecipient has access to information about projects operated by other subrecipients, necessary to ensure that subaward performance goals are achieved.
• Ensuring deliverables and payment are within the approved scope of the subaward.
• Responding to inquiries about the interpretation of subrecipient responsibilities under the subaward
• Processing and correcting invoices.
• Taking remedial action necessary to prevent the subrecipient from failing to perform its responsibilities under the subaward.
Condition: The county did perform subrecipient monitoring activities over the program as required by Treasury guidelines.
Cause: The county does not have policies and procedures in place that allow it to comply with subrecipient monitoring requirements outlined in the Uniform Guidance and Treasury guidelines.
Effect: Non-compliance with program terms and conditions.
Questioned Costs: None
Recommendation: The requirements for subrecipient monitoring for the subaward are contained in 31 USC 7502(f)(2) (Single Audit Act Amendments of 1996 (Pub. L. No. 104-156)), 2 CFR sections 200.332, and 200.501(h); federal awarding agency regulations; and the terms and conditions of the award. Management should develop procedures that will ensure compliance with the requirements.
Views of responsible officials and planned corrective action: The government agrees with this finding and will adhere to the attached corrective action plan.