Finding Text
Finding 2022-003 Criteria or Specific Requirement: The Code of Federal Regulations Section 200.322(b) states that the pass-through entity must evaluate the subrecipient's risk of noncompliance with Federal statutes and Section 200.332(d) states that the pass-through entity must monitor the activities of the subrecipient as necessary to ensure that the subawards is used for authorized purposes. Condition: During our review of subrecipient monitoring, it was noted that no formal written policy is maintained. Cause: The Organization does not have written policies and procedures to monitor subrecipient's activities in accordance with the Uniform Guidance requirements. Effect or Potential Effect: The deficiency increases the risk that subawards could be spent for purposes other than those outlined in the grant agreements. Context: The Organization provides subawards to grant recipients. Its monitoring procedures consist of approvals over the expenditures but lack the requirements set forth by 2 CFR 200.332. Questioned costs: None noted. Repeat finding: No. Recommendation: We recommend the Organization's subrecipient monitoring policies and procedures be reviewed and updated for compliance with the Uniform Guidance requirements. Additionally, we recommend the Organization review all policies and procedures annually, or more frequently, if necessary, to reflect changes to laws, regulations, personnel, and/or internal procedures. Views of Responsible Officials: Management agrees with the finding and will implement a process to documents its policies and ensure they meet the subrecipient monitoring requirements.