Finding Text
Condition: During the test of 100% of expenditures, two (2) expenditures totaling $570,080, for the Coronavirus State and Local Fiscal Recovery Funds, it was noted the County had one (1) subrecipient and the County did not have a subrecipient monitoring policy, and the County did not obtain subrecipient agreements comprising the following information:
• Subrecipient name.
• Subrecipient Authorized Representative and program contact information.
• Subrecipient Employee Identification Number (EIN) and DUNS number.
• Federal Award Identification Number (FAIN).
• Name of Federal Awarding Agency.
• Contact information for the official at the Federal Awarding Agency.
• Catalog of Assistance Listing (AL) number and name.
• Federal award date.
• Total amount of the federal award and indirect cost rate.
• Federal award project description.
• Start and end date of the agreement.
• Amount of federal funds budgeted for the agreement and indirect cost rate allowed.
• A statement that all activities must be in accordance with federal statutes, regulations, and terms and conditions of the federal award. The subrecipient should receive a copy of the award documents.
• A detailed description of any additional requirements you want the subrecipient to be responsible for such as performance and/or financial reports, attending meetings and/or trainings, etc.
• A statement about the monitoring activities, such as where/when they will take place; also include a statement indicating the subrecipient will collaborate on monitoring activities including providing requested financial documents.
• A statement indicating if any of the items in the agreement change during the period of performance, the agreement will be amended.
Provide close out terms and conditions.
Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal expenditures are made in accordance with compliance requirements.
Effect of Condition: This condition resulted in noncompliance with federal grant guidelines.
Recommendation: OSAI recommends the County gain an understanding of the requirements for this program and implement internal controls to ensure compliance with these requirements.
Management Response:
Board of County Commissioners: The Board of County Commissioners is responsible for the overall fiscal concerns of the county. See OKLA. STAT. Title 19, § 345. The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with all elected officials, the third-party administrator, and federal, state and local partners to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same. To assist in this process, the Board of County Commissioners engaged a third-party administrator to oversee the grant process, including application, eligibility, review, requirements, contracting, recipient tracking and oversight, and documentation and reporting. The Board of County Commissioners will work with the third-party administrator to ensure proper grant administration.
Criteria: 2 CFR 200 §200.332 Requirement for Pass-Through Entities states in part:
All pass-through entities must:
(a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the federal award and subaward.
(2) All requirements imposed by the pass-through entity on the subrecipient so that the federal award is used in accordance with federal statutes, regulations and the terms and conditions of the federal award.
(5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part.
(6) Appropriate terms and conditions concerning closeout of the subaward.