Finding Text
Section III. Federal Awards Findings and Questioned Costs
Finding 2024-001: Subrecipient Monitoring
Type of Finding: Material Weakness (MW), Instance of Noncompliance (NC)
Assistance Listing No.: 93.044, 93.045, 93.053, 93.052
Program Title: Title III - B Supportive Services and Senior Centers, Title III - C Nutrition Services, Nutrition Services Incentive Program, and Title III - E National Family Caregiver Support
Federal Award Year: 10/1/2023 - 9/30/2024
Federal Award No.: 2401PROASS, 2401PROACM, 2401PROAHD, 2401PROAPH, 2401PROANS
Name of Federal Agency: U.S. Department of Health and Human Services (HHS)
Name of Pass-through Entity: N/A
Criteria:
45 CFR Sections 1321.11(b) and 1321.17(f)(9), the State Agency is required to develop policies governing all aspects of programs operated under the State Plan and to monitor their implementation, including assessing performance for quality and effectiveness and specifying data system requirements to collect necessary and appropriate data. The policies developed by the State agency shall address the way the State agency will monitor the performance of all programs and activities initiated under this part for quality and effectiveness.
Statement of Condition:
OAE requires the monitoring process of 100% of the population of the subrecipients of federal funds, at least once a year. During the year ended September 30, 2024, the OAE distributed federal funds to 118 subrecipients. However, the subrecipients subjected to formal monitoring were only thirty-eight (38) or 32%.
Cause of Condition:
For the year ended September 30, 2024, the OAE had inefficient policies and procedures manuals that prevented the full monitoring of all centers. In order to improve efficiency, the OAE implemented a new risk assessment in April 2024 that will allow the centers to be monitored in a shorter time.
Effect of Condition:
The failure to monitor subrecipients may lead to inappropriate use of funds by the subrecipients, and the disallowance of such costs by the federal agencies.
Questioned Costs:
None.
Prior year finding: 2023-002
Recommendation:
OAE should review the design of the internal policies according to the available resources and modify what is established in the State Plan regarding the monitoring of subrecipients. The monitoring processes should be designed to ensure that the grants were used properly, and all supporting documents were properly assembled and stored. Best practices on subrecipients monitoring should be searched and evaluated for implementation.
View of Responsible Official and Planned Corrective Action Plan:
OAE agrees with the finding and will adhere to the corrective action plan on page 37 in this audit report.