System of Internal Controls Over Compliance: Subrecipient Monitoring; U.S. Department of Treasury, Assistance Listing #21.027, Coronavirus State and Local Fiscal Recovery Funds, Passed Through State of Nevada
Criteria: In accordance with 2 CFR 200.332, the auditee must maintain a system of internal
control over compliance to ensure they provide each subrecipient within the required appropriate document the performance of internal controls over the compliance for subrecipient monitoring.
Condition: The Organization did not appropriately implement internal controls necessary to ensure appropriate documentation was available to support the performance of controls in compliance with 2 CFR 200.332.
Context: The Organization did not identify funds being passed through from one subsidiary of the Organization to a second subsidiary in a timely manner and based on this timing did not appropriately document the performance of internal controls over the compliance of subrecipient monitoring.
Cause: The Organization did not identify its only subrecipient for this award in a timely
manner.
Effect: The Organization was not able to properly document its performance of internal
controls over most of the requirements outlined in 2 CFR 200.332 for the award based on
untimely identification of its subrecipient.
Recommendation: We recommend management design and implement a system of internal
controls over compliance where consideration of possible subrecipients is considered when the
award is being applied for and that well documented and supportable internal controls over
subrecipient monitoring are implemented when there are subrecipients identified under an
award.
Views of Responsible Officials and Planned Corrective Actions:
SJRC NV Region is addressing its missing controls related to the requirements of 2 CFR 200.332. We acknowledge that SJRC must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information required under 2 CFR 200.332 at the time of the subaward all requirements. This includes that every subaward is clearly identified to the subrecipient as a subaward and includes at the time of the subaward and if any data elements change, that there must be an approved subaward modification. We will also ensure we meet the requirements under 2 CFR 200.332 to include our obligations to risk assess and monitor any subrecipients.
The timeframe for correction is immediate and full accounting system control improvements will be implemented as part of our 2025 fiscal year-end close.
Submitted by:
Dr. Christina Vela, DPP
Chief Executive Officer
St. Jude's Ranch for Children, Inc. and its subsidiaries
cvela@stjudesranch.org