Finding Text
Federal Program: U.S. Department of Treasury, Assistance Listing # 21.023 - COVID-19 - Emergency Rental Assistance Program, Passed through the Pennsylvania Department of Human Services
Repeat Finding: 2021-005
Compliance Requirement: Subrecipient Monitoring
Criteria: The Uniform Guidance outlines various requirements for pass-through entities in Section 200.331, including the following items:
a) ensuring all subawards are clearly identify to the subrecipient as a subaward and include certain required information;
b) evaluate each subrecipient's risk of noncompliance with federal statutes, regulations and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring;
c) consider imposing specific subaward conditions upon a subrecipient, if appropriate;
d) monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations and the terms and conditions of the subaward;
e) depending on the pass-through entity's assessment of risk posed by the subrecipient, perform appropriate monitoring of the subrecipient;
f) verify that every subrecipient is audited as required by Subpart F of the Uniform Guidance;
g) consider whether the results of the subrecipient's audits, on-site reviews or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records, and;
h) consider taking enforcement actions against noncompliance subrecipients as described in Uniform Guidance section 200.338.
Condition/Context: The County does not have a formal risk assessment process, subrecipient monitoring policy or oversight program in place to monitor its subrecipients as required under the Uniform Guidance.
Questioned Costs: N/A
Effect: The County cannot be assured that the subrecipient complied with the program requirements, nor can it determine whether there should be adjustments to the County's records.
Cause: The County does not have the required written policies and procedures required by the Uniform Guidance related to subrecipient monitoring and as such, the County personnel overseeing subrecipients did not understand their responsibilities in regards to monitoring subrecipients.
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipient monitoring to provide guidance and a formal process for employees to follow when monitoring subrecipients.
Views of Responsible Officials and Planned Corrective Actions: The County understands and will seek to implement the necessary steps on a prospective basis.