Finding Text
2022-001 - Subrecipient Monitoring Federal Agency: U.S. Department of Health and Human Services Federal Program: Aging Cluster Programs (CFDA 93.044, 93.045, and 93.053) Material Weakness / Material Noncompliance Condition: We noted the required monitoring procedures were not performed or appropriately documented in accordance with 2 CFR 200.331. Criteria: Section 2 CFR 200.331 of the Uniform Guidance states that pass-through entities must evaluate each subrecipient?s risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. This evaluation may include, but is not limited to, (1) the subrecipient?s prior experience with the same or similar subawards; (2) the results of previous audit including whether or not the subrecipient receives a Single Audit and the extent to which the same or similar subaward has been audited as a major program; and (3) whether the subrecipient has new personnel or new or substantially changed systems. Based on the results of the evaluation, the Commission would then have to consider the extent to which monitoring procedures are required. At a minimum, the Commission must, (1) review financial and performance reports required by the Commission, (2) follow-up and ensure that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the Commission detected through audits, on-site reviews, and other means, and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the Commission as required by 200.521 of the Uniform Guidance. Additionally, the Commission must perform monitoring procedures as stipulated in the contracts between the Commission and subrecipients. Effect: Subrecipient monitoring procedures were not properly performed and documented by the Commission. Cause: There was no documentation of subrecipient risk assessments or monitoring procedures performed for grants provided to subrecipients for fiscal year 2022. Controls were not in place to ensure compliance with monitoring requirements. Questioned Costs: None. Recommendation: We recommend the Commission implement procedures to ensure risk assessments of subrecipients prior to each subaward is performed in accordance with the Uniform Guidance requirements and thoroughly documented. We further recommend that the required subrecipient monitoring be performed and documented for each subaward. Auditee Response and Corrective Action Plan: Management agrees with this finding. Refer to the corrective action plan in this report.