Finding 572503 (2023-002)

Finding 2023-002, Subrecipient Monitoring – Repeat Finding 2022-003, 2021-003 Federal Agency: U.S. Department of Health and Human Services Program Name: Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security Assistance Listing #: 93.318 Questioned Costs: None Condition/Context We tested a sample of three subrecipients. Sufficient evidence was not submitted to demonstrate that the Organization performed subrecipient monitoring in accordance with standards set forth in the Uniform Guidance. Criteria The Department of Health and Human Services requires recipients (i.e., Alianza Americas) to ensure monitoring of any subrecipient using federal funds to be consistent with the subrecipient monitoring standards set forth in the Uniform Guidance at 45 CFR 75.351 through 45 CFR 75.353, as applicable. In addition, Uniform Guidance requires that non-Federal entities establish and maintain internal control over the federal awards that provides reasonable assurance that the non-Federal entities are managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Cause The Organization did not monitor and review subrecipient activities in accordance with Uniform Guidance. Effect The Organization did not comply with Title 45 of the Code of Federal Regulations (CFR) Part 75 as it relates to subrecipient monitoring requirements. Recommendation We recommend that the Organization performs subrecipient monitoring in accordance with Uniform Guidance and that it updates its Policies and Procedures for Financial Management to include subrecipient monitoring processes in accordance with Uniform Guidance. Organization’s Management Response See corrective action plan.