Finding Text
Finding 2024-004: 10. 761 - U.S. Department of Agriculture - Water and Waste Technical Assistance and
Training - Material Weakness
Compliance
Requirement: Subrecipient Monitoring
Criteria: Per Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Subpart D, section
200.332, the non-Federal entity must determine the subrecipient is not excluded or
debarred or otherwise excluded from receiving Federal funds, as well as develop written
subrecipient monitoring policies and procedures.
Condition: During our testing of internal controls over compliance related to subrecipient monitoring,
we identified EWB-USA did not have written subrecipient monitoring policies or
procedures in place, nor determine that the subrecipient was not suspended or debarred
or otherwise excluded from receiving Federal funds. Additionally, EWB-USA did not
obtain a copy of the subrecipient's Uniform Guidance compliance audit.
Questioned Costs: None.
Cause: EWB-USA did not have adequate controls in place to ensure compliance with applicable
federal requirements. Effect: EWB-USA was not in compliance with the subrecipient monitoring provisions as
prescribed in the Uniform Guidance.
Recommendation: We recommend that EWB-USA adopt formal, written subrecipient monitoring policies
and procedures the comply with the Uniform Guidance.
Response: 1. Develop a policy for subrecipient monitoring, and implement procedures to
oversee the programmatic and financial activities of subrecipients and ensure
compliance with regulations.
2. Develop a standardized checklist to guide the monitoring of subrecipients.
3. Provide training to relevant staff on the new procedures for subrecipient
monitoring and the importance of compliance with federal regulations.