Finding 571927 (2024-003)

Criteria: 2 CFR 200.332 establishes requirements for pass-through entities. Included in these requirements is to monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. Condition: The City did have procedures in place to monitor allowable costs and activities of its subrecipients. However, while conducting a review of expenditures through the monitoring of the Appalachia Community Grant (ACG), the Ohio Department of Development (ODOD), noted that a subrecipient of the City had made unallowable expenditures for the grant. This demonstrates a control weakness in the subrecipient monitoring controls conducted by the City. Context: The City, ODOD, and the subrecipient are working on a way to recover any questioned costs associated with this and these do not represent questioned costs of the City. Effect: There is a significant deficiency in the subrecipient monitoring controls of the City that could allow future unallowable costs or activities at subrecipients, if not improved. Recommendation: We recommend that the City implement stronger monitoring controls including vendor verification and review of invoices for the draw down requests that they receive from their subrecipients.