Finding Text
Federal Program: AL 11.307 – Economic Adjustment Assistance
Criteria: Uniform Guidance requires, for any funds passed through to a subrecipient, that the
pass-through entity (The Chamber Foundation) must perform certain activities to ensure that the
subrecipient uses funds within provisions of the grant award and Uniform Guidance (2 CFR
sections 200.331 (d) through (f)). This includes review of independent audits of subrecipients
and response to deficiencies detected through audits (2 CFR section 200.331(f)). It also
includes requiring all subawards granted to subrecipients have specific identifications with the
award to ensure the subaward is clearly identifiable (2 CFR Section 200.331(a)).
Condition: For the four-month period from September 1, 2024 through December 31, 2024, we
reviewed the Foundation’s subrecipient internal controls, requesting supporting documentation
for monitoring activities included, and interviewed key members of management when
documentation was not available. Performance of several of the policies noted as required
under Unform Guidance for subrecipient monitoring and per the Foundation’s internal controls
could not be substantiated or were determined to not have occurred during the year under audit.
Cause: Due to internal control deficiency noted in 2024-001, the subrecipient monitoring
requirement was not in compliance during the year.
Context: Of the federal expenditures under the program noted, $91,125 are passed through to
subrecipients. The following are specific items noted that were not in compliance with the
criteria listed above:
- We requested copies of the correspondence with subrecipients requesting copies of the
financial statement audits performed in compliance with 2 CFR 200. Follow up
discussion with the Chamber Foundation staff confirmed that this requirement was not
completed during the year under audit. Subsequently, of the four subrecipient audit
reports required to be requested, zero were requested.
- We requested copies of all subawards awarded to subrecipients. Of the four subawards
awarded to pass-through entities, one was missing the following required information
under (2 CFR Section 200.331(a)):
o Subrecipient’s unique entity identifier.
Effect: Increased risk of potential noncompliance with subrecipient monitoring requirements
under Uniform Guidance.
Questioned costs: None
Recommendation: The Foundation should request yearly audit reports as determined by 2 CFR
200. Additionally, the entity should include all required information as determined in CFR
Section 200.331(a) in all subawards.
Views of Responsible Officials: Management recognizes the deficiency and plans to implement
the auditor’s recommendations.
Indication of Repeat Finding: This is a repeat finding of August 31, 2024 - 003 from the prior
year.