Finding Text
Criteria or Specific Requirement
OMB’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (UG) requires that a pass-through entity must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information as required in 2 CFR 200.332(b).
Condition and Context
During our audit, we tested a sample of two subrecipients for each assistance listing number in order to determine if the subrecipient agreements contained all required elements per 2 CFR 200.332(b) and ensure sufficient subrecipient monitoring procedures were performed. As a result of our testing, it was identified that the agreements tested did not contain the subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate.
Cause
The Organization did not have adequate controls in place to ensure all required elements were included in subrecipient agreements.
Effect or Potential Effect
Due to the weakness in internal controls and compliance finding noted above, the Organization did not comply with the requirements of the Uniform Guidance regarding communication to subrecipients all the specified elements in 2 CFR 200.332. No questioned costs are reported as this requirement is administrative in nature.
Recommendation
The Organization should address the weakness noted above and update its subrecipient agreements, policies, and procedures to ensure that all required elements are present to comply with the Uniform Guidance.
Views of Responsible Official
Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.