Finding 560792 (2024-003)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-05-19

AI Summary

  • Core Issue: Astraea failed to conduct required risk assessments for all subrecipients, leading to potential oversight gaps.
  • Impacted Requirements: Noncompliance with 2 CFR 200.331 and 2 CFR 200.332(a) due to missing risk assessments and incomplete subrecipient agreements.
  • Recommended Follow-Up: Ensure adherence to subaward policy by completing risk assessments for all subrecipients and updating agreements to include all required elements.

Finding Text

Finding 2024-003: Subrecipient Management and Monitoring (Material Weakness) Information on the Federal Programs: Assistance Listing Number 98.001 Criteria: As stated in 2 CFR 200.331 part (b), all pass-through entities must 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 procedures to prescribe to each individual subrecipient. Additionally, per 2 CFR 200.332(a), pass-through entities must include specific information in subrecipient agreements, such as the Assistance Listing Number (ALN), compliance requirements, and monitoring responsibilities, to ensure proper oversight and accountability. Condition: Astraea has a subaward policy, which requires a risk assessment form be completed for each potential subrecipient. However, this step was not completed for all of the subrecipients in which Astraea engaged with during the fiscal year. Furthermore, during our review of subrecipient agreements, we noted that certain agreements did not contain all the required elements as outlined in 2 CFR 200.332(a). Cause: Astraea did not adhere to its policy in regards to risk assessment procedures. Additionally, Astraea did not have formalized procedures for ensuring all required elements, including the ALN, were included in subrecipient agreements. Context: Astraea failed to perform risk assessment procedures. Our audit work in this area consisted of substantive testwork over a sample of subrecipient expenditures that were selected based on a defined threshold. We consider our sample to be representative of the populations, and thus, is a statistically valid sample. The issue is deemed to be systemic. Additionally, during our review of subrecipient agreements we noted two that did not include the required ALN, which is necessary to properly identify the source of Federal funding. Effect: Astraea could inadvertently engage in relationships with subrecipients of higher risk without the appropriate level of oversight (i.e. monitoring) to ensure subrecipients are expending funds in accordance with the provisions and terms of the subaward. Additionally, the absence of required information in subrecipient agreements increases the risk of noncompliance with Federal grant requirements and improper use of Federal funds.Questioned Costs: None noted. Identification as a Repeat Finding, if Applicable: Finding 2023-004 Recommendation: We recommend Astraea adhere to its current subaward policy and ensure the risk assessment procedures over all of its subrecipients are performed and documented prior to engagement. Based on these risk assessments, Astraea should assign a risk level to each, and then determine the monitoring tools to apply based on these risk levels. We also recommend Astraea require its subrecipients to submit financial reports demonstrating use of each advance before advancing more funds, to ensure subrecipients are expending funds appropriately. Furthermore, Astraea should implement enhanced review procedures to ensure all subrecipient agreements include the required information before execution, such as, updating standard agreement templates.

Corrective Action Plan

Views of Responsible Officials: Over the past three (3) years, the organization has increased the skill set and capacity among teams for risk assessment and awards management. Subaward policies have been reviewed and all subaward recipients are required to complete pre-award surveys (which include the risk assessment unless the subrecipients are pre-approved by USAID and exempted from such policies). The Associate Director of Grants and Compliance continues to work with members of the Program team to monitor all subrecipient awards for full compliance with 2 CFR 200.516(a). After the FY2022 findings, Astraea sought documentation from federal agencies where risk assessment exemptions applied. The inception of some of these subawards predated FY2022. While we had intended to perform new retroactive risk assessments, the suspension of the federal awards as of January 24, 11:59PM and subsequent termination of the awards had clear instructions to stop work, and therefore made such requests impossible.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 560791 2024-002
    Material Weakness Repeat
  • 560793 2024-004
    Material Weakness Repeat
  • 1137233 2024-002
    Material Weakness Repeat
  • 1137234 2024-003
    Material Weakness Repeat
  • 1137235 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $2.77M
19.345 International Programs to Support Democracy, Human Rights and Labor $244,741