Finding Text
Finding 2024-001
Subrecipient Monitoring – Material Weakness in Internal Control over Compliance and Material Noncompliance
Agency
Department of Justice
Assistance Listing Number (ALN)
16.838
Program Name
Comprehensive Opioid, Stimulant, and Substance Use Program
Award Year
2024
Criteria
In accordance with 2CFR Part 200 Subpart D, the City was required to clearly identify a subaward to the recipient with federal award identification information and requirements for compliance with Federal statutes, regulations and the terms and conditions of the Federal award.
The City was further required to communicate to its subrecipients the relevant requirements to determine suitability of certain individuals interacting with minors and have written procedures in place to respond in the event of an actual or imminent breach of personal identifiable information.
Condition
Subrecipient agreements were not issued with required Federal award information. Further, relevant compliance requirements were not communicated to the subrecipients.
Cause
The program was new for the City and was managed by a department that was not familiar with subrecipient disclosure requirements.
Effect or potential effect
Sub awardees and the Federal government did not receive complete award information and were not informed of relevant grant-specific compliance requirements.
Context
There were three subrecipients under the program. In 2024, subrecipient expenditures totaled $196,880.
Identification as a repeat finding
N/A
Recommendation
The City should implement internal control procedures to evaluate applicability of grant requirements, especially when funding sources or nature of grant awards change. Subrecipients should receive correct Federal award information and be reported as required under FFATA.
Views of Responsible Official and Planned Corrective Action
Management agrees with the finding. Subaward agreements will be issued to organizations that received COSSUP funding during the terms of the grant over $30,000. Future internal controls will include review by the Finance Director and the Controller to evaluate grant requirements.