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.