Finding Text
2021-005 – SUBRECIPIENT MONITORING – SUBAWARD AGREEMENTS
Federal Program Information:
Federal Agency
Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s)
Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001
W15QKN-20-1-1000
Criteria:
2 CFR 200.303 requires that a non-federal entity must “(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award.” These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Subrecipient agreements must make the subrecipient aware of the award information required by 2 CFR section 200.331(a):
(1) Determines who is eligible to receive what Federal assistance;
(2) Has its performance measured in relation to whether objectives of a Federal program were met;
(3) Has responsibility for programmatic decision-making;
(4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
(5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.
Furthermore, DoDGAR’s Appendix B Part 22 requires agreements make the subrecipient aware of federal provisions related to Nondiscrimination; Debarment and Suspension; Hatch Act; Environmental Standards; Drug-Free Workplace and other federal regulations.
Condition:
Standard Subrecipient agreements did not make reference to certain provisions which are required to be contained in the agreement.
Questioned Costs:
Not applicable.
SECTION III – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (Continued)
2021-005 – SUBRECIPIENT MONITORING – SUBAWARD AGREEMENTS (Continued)
Federal Program Information:
Federal Agency
Federal Program Name Assistance Listing Number Grant Award(s) Unique Identifier(s)
Department of Defense Basic Scientific Research 12.431 W15QKN-14-1-0001
W15QKN-20-1-1000
Context:
There were twelve Subrecipient agreements executed during the year under the federal award with total expenditures of $2,086,200. Total federal expenditures listed on the Schedule of Federal Awards was $6,267,848.
Cause:
Internal controls and procedures related to Subrecipient monitoring requirements were not effectively designed or performed.
Effect:
The National Center for the Advancement of STEM Education, Inc. did not adequately include certain necessary language in the executed agreements to properly comply with Subrecipient monitoring.
Recommendation:
Management should establish proper policies and procedures which ensure Subrecipient agreements comply with applicable federal guidelines.
Views of Responsible Officials:
Management concurs with the finding and has developed a plan to correct the finding.