Finding 569440 (2024-001)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-06-30
Audit: 360924
Auditor: Wipfli LLP

AI Summary

  • Core Issue: There is a material weakness in internal controls regarding compliance with federal program requirements, specifically in subrecipient monitoring.
  • Impacted Requirements: The organization failed to include necessary information in subawards as mandated by the Uniform Guidance, which affects compliance with federal standards.
  • Recommended Follow-Up: Management should revise subawards to include all required details and establish a process for reviewing subrecipients' audited financial statements.

Finding Text

Finding Number 2024-001: Represents a material weakness in internal control over compliance and material noncompliance with Maine Community Action Association d/b/a Maine Community Action Partnership's major federal program. Repeat Finding: No Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance Description: Subrecipient Monitoring over Federal Awards Major Program: AL#93.647 - Social Services Research and Demonstration - Award numbers 90XP0450-01-05 and 90EDA0019-01-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: Single audit procedures noted that the subrecipient grant awards do not include the required wording in accordance with the Uniform Guidance and the Organization does not have a procedure for reviewing audited financial statements of subrecipients. Criteria: 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.332(b) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. Required information includes: (1) Federal award identification. (i) Subrecipient's name (must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated in the subaward; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obliation: (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) (xi) Name of the Federal agency, pass-through entity, and contact information for awarding official of the pass-through entity; 25 (xii) Assistance Listing title and number; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listing Number at the time of disbursement. (xiii) Identification of whether the Federal award is for research and development; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with §200.414 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, §200.332(b)(g). An entity must verify that a subrecipient is audited as required. Cause: The Organization's subawards do not contain all of the required language and the Organization's policy and procedures related to subrecipient monitoring does not include a process for reviewing audits of subrecipients. Effect: The Organization was not in compliance with Uniform Guidance standards for requirements to monitor pass-through entities of federal awards. Recommendations: Management should update their subawards to include all of the required language and update their policies and procedures to include a process for reviewing audited financial statements of subrecipients. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Corrective Action Plan

Corrective Action Plan for Current Year Findings Grantee Name: Maine Community Action Association d/b/a Maine Community Action Partnership (MeCAP) Federal Program: AL 93.647 – Social Services Research and Demonstration Finding Reference: 2024-001 Type of Finding: Material Weakness in Internal Control Over Compliance and Material Noncompliance with Subrecipient Monitoring CFDA Number: 93.647 Award Numbers: 90XP0450-01-05 and 90EDA0019-01-00 Fiscal Year: 2024 Finding Summary: The auditor identified that subrecipient agreements under the 93.647 program did not include all elements required by 2 CFR §200.332(a), and that MeCAP lacked a documented procedure for obtaining and reviewing subrecipient audit reports. Corrective Action Plan: 1. Subaward Template Revision MeCAP will revise its standard subrecipient agreement template to include all Uniform Guidance–required elements as outlined in 2 CFR §200.332(a), including but not limited to: • Federal Award Identification (FAIN, ALN, federal agency name) • Period of performance and budget • Federal award project description • Indirect cost rate (including identification of the de minimis rate, if applicable) • FFATA reporting requirements • R&D identification (if applicable) • Contact information for the awarding official A revised template will be implemented and used for all active and future subawards beginning July 15, 2025. 2. Subrecipient Audit Review Procedures MeCAP will implement a formal policy and internal control procedure to: • Obtain and review the Single Audit reports of all subrecipients who expend $750,000 or more in federal awards annually; • Use the Federal Audit Clearinghouse and/or direct communication with the subrecipient to obtain the report; • Review audit findings for relevance to the MeCAP-administered program and assess any required follow-up or risk mitigation actions; 240 Bates Street | Lewiston, ME 04240 • Document this review in the subrecipient’s monitoring file. The procedure will be included in the Organizational Policies and Procedures Manual and communicated to all program and fiscal staff by August 15, 2025. 3. Training and Internal Communication Program and finance staff responsible for subrecipient oversight will participate in a training session covering: • Uniform Guidance subrecipient monitoring requirements • Changes to the subaward template • The audit review protocol Training will be conducted internally or through a third-party training provider by September 30, 2025. Person(s) Responsible: Executive Director, MeCAP Lawrence Rugg Contracted Fiscal Management, Fiscal Innovations Inc. Expected Completion Date: September 30, 2025

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 569441 2024-001
    Material Weakness
  • 1145882 2024-001
    Material Weakness
  • 1145883 2024-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.647 Social Services Research and Demonstration $356,839
84.310 Statewide Family Engagement Centers $78,756
93.569 Community Services Block Grant $55,021