FAC Explorer

Finding 598043 (2022-002)

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Requirement
M
Questioned Costs
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Year
2022
Accepted
2023-03-30
Audit: 27412
Organization: Montgomery County, Maryland (MD)
Auditor: Sb & Company LLC

AI Summary

  • Core Issue: The County failed to properly inform subrecipients about Federal requirements in their agreements, leading to non-compliance with monitoring standards.
  • Impacted Requirements: Agreements lacked necessary disclosures as outlined in 2 CFR section 200.331, affecting compliance with Uniform Guidance.
  • Recommended Follow-Up: Develop a standardized subaward template that includes all required disclosures and ensure its consistent use for all subaward contracts.

Finding Text

Finding 2022-002 U.S. Department of Health and Human Services Assistance Listing Number 93.044, 93.045, 93.053 ? Aging Cluster Non-compliance with Subrecipient Monitoring Repeat Findings: No Criteria: A pass-through entity (PTE) must clearly identify to the subrecipient the award as a subaward at the time of subaward (or subsequent subaward modification) by providing the information described in 2 CFR section 200.331(a)(1); all requirements imposed by the PTE on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award (2 CFR section 200.331(a)(2)); and any additional requirements that the PTE imposes on the subrecipient in order for the PTE to meet its own responsibility for the Federal award (e.g., financial, performance, and special reports) (2 CFR section 200.331(a)(3)). Condition and Context: For 6 out of 6 selections, the agreement with the subrecipient did not clearly identify the Federal assistance listing. Additionally, the agreement did not contain the information described in 2 CFR section 200.331(a). Cause: The County did not inform its subrecipients of Federal requirements included in Uniform Guidance related to procedures required for subrecipient monitoring. Effect or Potential Effect: The subrecipient may not be in compliance with Uniform Guidance, therefore causing the County to not be in compliance with Uniform Guidance. Questioned Costs: Unknown. Recommendation: We recommend that the County creates a subaward template document that includes all of the required disclosures per the Uniform Guidance, and ensure that the document is used to prepare all subaward contracts throughout the County. Views of Responsible Officials: The County agrees with the finding and notes that the required disclosures per the Uniform Guidance are presented to departments during the Department of Finance?s annual year-end training sessions. This material is available for departments to refer back to throughout the year. The Department of Finance will work to ensure these requirements are presented to targeted individuals who are responsible for subaward contracts. See Section V for the corrective action plan.

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
21.027 American Recovery Plan Act (arpa) $40.90M
20.507 American Recovery Plan Act (arpa) $39.06M
14.239 Home Investment Partnerships Program - Outstanding Balance Beginning of the Year $36.76M
21.023 Emergency Rental Assistance Program (erap) $28.22M
21.019 Coronavirus Response and Relief Supplemental $23.06M
93.778 Federal Financial Participation - Title Xix $17.87M
21.019 Corona Virus Relief Fund (crf) $17.04M
14.218 Community Development Block Grant (cdbg) $13.77M
93.778 Frs Ambulance Fees $9.35M
10.561 State Administrative Matching Grant for Food Stamps $8.80M
93.558 Temporary Assistance for Needy Families $7.49M
93.778 Title Xix - Certification $5.96M
97.067 Fema Reimbursements $4.35M
93.658 Title IV-E Administration $2.67M
93.778 Medical Assistance $2.65M
20.937 Capital Projects $2.13M
93.268 Covid Mass Vaccination Cares $2.11M
93.667 Social Services Block Grant Ssbg $2.08M
93.323 Enhancing Detection Grant-Elc $1.86M
12.600 Maryland Crossing Route 355 $1.77M
93.568 Low Income Home Water Assistance $1.74M
93.778 Parents with Children Count Eligibility $1.72M
93.917 Ryan White B Supplemental $1.67M
14.231 Emergency Solutions Grant (esg) $1.60M
93.268 Immunovaccines for Children Covid #4 $1.59M
93.568 Low Income Home Energy Assistance $1.42M
93.778 Medicaid Transport $1.27M
84.181A Infants and Families with Disabilities Part C $1.20M
93.686 End the Hiv Epidemic $968,990
97.025 Tropical Cyclone Ida $939,590
14.241 Housing for People with Aids (hopwa) Covid-19 $881,947
93.778 Connector Entity Program for Navigator Services $802,211
93.575 Infant & Toddlers State Grant. $769,294
93.044 Care Act Title III $711,707
93.569 Community Services Block Grant (csbg) $651,906
84.027A Infants and Families with Disabilities Part B 611 $612,400
93.044 Title Iiib - Supportive Services $605,595
93.563 Child Support Enforcement $596,491
93.940 Hiv Prevention Activities Health Department Based $574,330
97.067 Ff2019 (linx) Law Enforcement Info Exchange $572,488
93.958 Community Mental Health Services $564,198
93.778 Administrative Care Coordination $514,188
93.917 Ryan White II - Consortia Services $492,293
93.069 Public Health Emergency Preparedness $480,430
97.025 National Urban Search & Rescue System Readiness $471,609
93.788 State Opioid Response (sor) $462,452
93.940 Implement Ending Hiv Epidemic $453,007
93.778 Infants & Toddlers - Clig - Medicaid $408,369
93.570 Csbg Supplemental - Cares $397,695
93.914 Ryan White A $397,211
97.067 Ff2021 Regional Preparedness System $395,005
93.052 Hhs Tiiie - Caregiver $391,835
97.067 Ff2020 Tactical Equipment for Law Enforcement $390,637
93.563 Title IV-D - Child Support $375,157
93.778 Title Xix - Health Related Services $369,620
93.268 Immunization-Hep-Iap,hep-B $327,168
97.067 2021 Empg $327,001
14.267 Continuum of Care Homeless Assistance $317,117
93.600 Head Start $313,194
17.575 Multicultural Intervention of Child Abuse $309,232
93.959 Prevention and Treatment of Substance Abuse $301,481
93.354 Cdc Crisis Cooperative Agreement $285,345
93.645 Title IV-B Child Welfare Services $283,823
93.767 Children Insurance Program (chip) $270,767
93.767 Pwc/md Kids Count Eligibility. $269,449
17.575 Fy22 Hhs Victim Assistance Services $267,317
16.034 Public Safety Covid-19 Emergency Supplemental Grant $254,745
97.067 Ff2020 Regional Preparedness System $253,650
93.575 Professional Development Capacity Building $244,449
14.239 Home Investment Partnerships Program $226,828
93.747 Adult Protective Services $226,366
93.116 Tuberculosis Control $225,926
97.067 2020 Shsp $221,830
12.003 Base Realignment and Closure (brac) $198,282
97.044 Assistance to Firefighters Exhaust Grant $186,222
97.067 Ffy20 Emergency Management $176,903
93.788 Access Harm Reduction $173,456
93.575 Early Childhood Mental Health. $165,400
93.671 Comprehensive Domestic Violence Services $142,238
97.067 Ff2020 Volunteers and Donations Management $132,468
16.034 Byrne Supplemental Covid-19 Grant $126,387
93.136 Community Bh-Adult Substance Use Disorder Services $121,587
93.045 Title Iiic1 - Congregate Meals $121,358
97.067 Ffy20 Emerging Homeland $120,814
93.898 Early Detect & Control Breast Cancer $113,791
17.575 Sexual Assault Rape Crisis Intervention $112,132
93.940 Hiv Partner Services $110,602
97.067 Ffy20 Radio Cache $109,801
93.659 Title IV-E - Adoption $108,514
93.052 Senior Medicare Patrol $104,687
93.959 One-Time Covid19 Supplement for Prevention Services $102,346
17.575 Fy22 Sao Victim Services $102,291
14.241 Housing for People with Aids (hopwa) $101,833
93.150 Path - Transition From Homelessness $100,794
93.324 Medicare Improvements for Patients and Providers $91,886
97.067 Ffy21 Empg-Arpa $89,558
17.575 Sexual Assault Victims Services $87,970
93.556 Family Preservation $85,299
94.002 Retired and Senior Volunteer Program $83,498
97.067 Ff2019 Public Health Emergency Response $80,669
97.067 Ff2019 Radio Cache (ncrcig) $78,639
17.575 Fy21 Hhs Victim Assistance Services $78,261
16.741 Ffy19 Dna Backlog $76,649
97.067 2019 Shsp $75,460
93.959 Overdose Misuse Prevention $73,552
93.994 Caring for Children with Special Needs $72,706
14.261 Homeless Management Information Capacity Building Project $68,092
93.829 Samhsa Crisis 2 Connection $65,524
93.959 Integration of Sexual Health & Recovery $64,268
97.025 Champlain Tower Collapse $64,175
16.738 Bjag Byrne Local Block Grant $63,909
16.034 Montgomery County Hhs Covid-19 $61,860
20.616 Pol Mdot Sha Impaired $59,225
93.959 American Rescue Plan One-Time Supplemental Funding $57,687
84.173 Infants and Families with Disabilities Part B 611 $57,081
16.588 Stop Domestic Violence $56,615
93.069 Cities Readiness Initiative $56,336
93.777 Nursing Home Reimbursement $55,236
16.742 McPd Coverdell Fy21 Tackling An Increase in Gun Crime $43,825
16.741 Ffy20 Dna Backlog $41,831
97.067 Ffy20 Public Access Bleeding $40,400
16.588 Protective Order Enforcement Project $40,088
97.067 Ff2019 Tactical Equipment for Law Enforcement $39,805
97.067 2019 Planning and Exercises $39,800
93.053 Nutrition Service Incentive Program $37,500
16.738 Wellness for Call Takers and Dispatchers $37,309
97.067 2019 Public Health Emergency $37,238
93.043 Title Iiid - Preventive Health $35,929
97.067 2021 Uasi Linx Baltimore $35,404
97.067 Ff2019 Volunteers and Donations Management $31,980
93.778 Assistance and Community Integration Services (acis) $30,375
93.767 Assistance and Community Integration Services (acis) $30,375
97.067 Ff2019 Public Access Bleeding $29,680
97.067 Ff2019 Emergency Operations Center Enhancements $28,811
17.278 Welcome Back Center $28,085
97.067 Ff2019 Unmanned Aerial Systems $26,632
16.111 Regional Fugitive Gang Task Force $25,489
93.048 Title Iiid - Preventive Health $25,277
20.616 Impaired Driving Enforcement $25,035
17.259 Welcome Back Center $24,290
93.323 Enhancing Detection Grants - Elc $24,149
93.323 Covid-19 Community Health Worker $24,149
17.258 Welcome Back Center $23,530
97.067 2020 Empg $22,073
45.310 Staff Development Grant $21,261
93.434 Early Childhood Advisory Councils Quality Improvement Grant $19,557
20.600 Aggressive Driving $18,186
94.014 Martin Luther King Volunteer Day Grant $16,899
16.575 Fy21 Sao Victim Services $16,113
97.067 Ffy2021 Radio Cache $14,616
93.600 Head Start - Arpa $14,595
93.042 Title IV - Ombudsman $13,065
97.067 Ffy21 Emergency Mgmt. Planning $12,143
93.071 Medicare Improvements for Patients and Providers $11,754
93.958 Samhsa Block Grants for Community Mental Health Services $11,177
93.043 Title IV - Ombudsman $11,036
93.041 Title IV - Elder Abuse Prevention $9,950
93.071 Hhs Tiiie - Caregiver $9,100
97.025 Kentucky Tornadoes $7,140
93.090 Title IV-E Guardianship $7,091
97.067 Ffy20 Incident Command Tools $6,132
16.588 Lethality Assessment Advocate $5,897
20.616 Speed/driving Enforcement Award $5,434
84.181 Idea Arpa $5,190
93.959 Start Family Mentor Program $5,081
93.042 Title IV - Elder Abuse Prevention $4,807
93.044 Expanding Access to Covid-19 Vaccines $4,617
97.067 Ff2021 Volunteers and Donations Management $3,612
84.027A Infants and Families with Disabilities $2,700
93.788 Sor Mat in Jail $2,302
93.669 Child Abuse $1,046
97.025 59th Presidential Inauguration $478