Finding 554775 (2023-004)

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Requirement
M
Questioned Costs
-
Year
2023
Accepted
2025-04-11

AI Summary

  • Core Issue: The Center failed to include required information in all 7 sub-awards to subrecipients, particularly the Assistance Listing Number (ALN).
  • Impacted Requirements: Compliance with 2 CFR 200.332, which mandates that pass-through entities provide specific details in sub-awards to ensure subrecipients understand their federal funding obligations.
  • Recommended Follow-Up: The Center should implement a review process for contracts to ensure all future sub-awards meet the necessary criteria outlined in the Uniform Guidance.

Finding Text

Adult Education-Basic Grants to States-ALN #84.002; U.S. Department of Education; Pass-Through Entity – Pennsylvania Department of Education Criteria: 2 CFR 200.332 states that all pass-through entities must ensure that every sub-award is clearly identified to the subrecipient as a sub-award and includes the following information at the time of the sub-award and if any of these data elements change include the changes in subsequent sub-award modification. When some of this information is not available, the passthrough entity must provide the best information available to describe the Federal award and sub-award. Required information includes: Federal Award Identification which includes: (i) subrecipient name; (ii) subrecipient's unique entity identifier; (iii) Federal Award Identification Number; (iv) Federal Award Date; (v) Sub-award Period of Performance Start and End Date; (vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current obligation; (viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act; (x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xi) Assistance Listing Number (ALN) and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; (xii) Identification of whether the award is R&D and (xiii) Indirect cost rate for the Federal award. Condition: The Center receives federal money to provide Adult Basic Education, General Education Development (GED), family literacy, career assessment and career and job-skills training for the underprivileged of the community. In order to carry out those services, the Center enters into sub-awards with providers throughout its service territory. A review of 7 sub-awards that were deemed to be subrecipients disclosed that all 7 sub-awards did not contain the required information that is to be identified to subrecipients, particularly the ALN. Context: The Center has been providing Adult Basic Education, General Education Development (GED), family literacy, career assessment and career and job-skills training for the underprivileged of the community services under a grant received from the Pennsylvania Department of Education In order to provide the services, sub-awards are made with providers within the Center’s service territory. The sub-awards are required to have certain information disclosed so the subrecipient can comply with the applicable compliance requirements from the funding source. Cause: The Center did not have a process in place to ensure that all sub-awards to subrecipients were reviewed to ensure all required information was included in the agreement. Effect: The subcontractor may have been unaware they were receiving federal funds. As such providers may have been unaware of the applicable compliance requirements. Questioned Costs: None. Repeat Finding: This was not a repeat finding. Recommendation: We recommend the Center review its contracts against the criteria set forth in the Uniform Guidance to ensure that all sub-awards in the future contain the required information for subrecipients. View of Responsible Officials: Management has responded to this finding in the Corrective Action Plan which is part of this reporting package.

Corrective Action Plan

Recommendation: We recommend the Center review its contracts against the criteria set forth in the Uniform Guidance to ensure that all sub-awards in the future contain the required information for subrecipients. Action Taken: Tri-County 010 has taken the following corrective steps: Reviewed and Updated the Subrecipient Contract Template to include all required elements as outlined in Pennsylvania Department of Education. Implemented a Pro-Award Contract Review Checklist to ensure each contract is verified for compliance prior to execution. Established a Documentation Process for storing all subrecipient agreements and related compliance materials in a centralized location. Anticipated Completion Date: March 31, 2025 Contact Person Responsible: Christina Johnson, Executive Director

Categories

Subrecipient Monitoring Period of Performance Reporting

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.002 Adult Education - Basic Grants to States $209,500
17.270 Reentry Employment Opportunities $166,313
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $9,625