FAC Explorer

Finding 614013 (2022-005)

Significant Deficiency
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 32371
Organization: City of Boston (MA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: The City of Boston's Age Strong Commission failed to include all required elements in subaward letters as mandated by 2 CFR Section 200.331(a).
  • Impacted Requirements: Missing details include whether the subaward is for R&D and the indirect cost rate, leading to inadequate controls over subrecipient notifications.
  • Recommended Follow-Up: Update the Memorandum of Agreement (MOA) with subrecipients to ensure compliance with all Uniform Guidance requirements.

Finding Text

Finding number: 2022 005 Federal agency: U.S. Department of Health and Human Services Pass through agency: Massachusetts Executive Office of Elderly Affairs Program: Aging Cluster ALN #: 93.044, 93.045, 93.053 Award number: Various Award year: Various Finding: Internal Control over Subrecipient Monitoring Prior Year Finding: No Type of Finding: Significant Deficiency Criteria 2 CFR section 200.331(a) indicates that all pass through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification: (1) Federal Award Identification. ? Subrecipient?s name (which must match registered name in DUNS); ? Subrecipient?s DUNS number (see ? 200.32 Data Universal Numbering System (DUNS) number); ? Federal Award Identification Number (FAIN); ? Federal award date; ? Subaward Period of Performance Start and End Date; ? Amount of Federal Funds Obligated by this action; ? Total Amount of Federal Funds Obligated to the subrecipient; ? Total Amount of the Federal Award committed to the subrecipient by the pass through entity; ? Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ? Name of Federal awarding agency, pass through entity, and contact information for awarding official of the pass through entity; ? ALN Number and Name; the pass through entity must identify the dollar amount made available under each Federal award and the ALN number at time of disbursement; ? Identification of whether the award is R&D; and ? Indirect cost rate for the Federal award (including if the de minimis rate is charged per ? 200.414 Indirect (F&A) costs). (2) All requirements imposed by the pass through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award. (3) Any additional requirements that the pass through entity imposes on the subrecipient in order for the pass through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved Federally recognized indirect cost rate negotiated between the subrecipient and the Federal government or, if no such rate exists, either a rate negotiated between the pass through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ? 200.414 Indirect (F&A) costs, paragraph (b) of this part. (5) A requirement that the subrecipient permit the pass through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the passthrough entity to meet the requirements of this section, ? 200.300 Statutory and national policy requirements through 200.309 Period of performance, and Subpart F ? Audit Requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition During our testing of subrecipient monitoring for a sample of 8 out of the population of 20 subrecipients, the City of Boston?s Age Strong Commission (Age Strong Commission) subaward letters were authorized however it was noted that such documents did not contain all of the required elements of 2 CFR Section 200.331(a) listed above. For all 8 subrecipients, the subaward letter did not identify whether the subaward is R&D and did not contain the indirect cost rate for the Federal award. Cause This appears to be due to inadequate review to ensure the subaward includes all of the required elements of 2CFR Section 200.331(a) prior to authorization. Effect Aging does not have adequate controls over subrecipient notification requirements. Whether Sampling was Statistically Valid The sample was not intended to be, and was not, a statistically valid sample. Questioned Costs: None Recommendation We recommend that OEM execute an updated MOA with its subrecipients that expressly includes all information description in 2 CFR section 200.331(a)(1) as required by the Uniform Guidance. View of Responsible Officials from the Auditee The City of Boston?s Age Strong Commission has revised the addendum that is attached to their award letters to include whether or not the award is R&D and a section on indirect cost rate.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 37561 2022-001
    Material Weakness
  • 37562 2022-002
    Significant Deficiency
  • 37563 2022-003
    Material Weakness Repeat
  • 37564 2022-004
    Material Weakness
  • 37565 2022-005
    Significant Deficiency
  • 37566 2022-006
    Significant Deficiency
  • 37567 2022-005
    Significant Deficiency
  • 37568 2022-006
    Significant Deficiency
  • 37569 2022-005
    Significant Deficiency
  • 37570 2022-006
    Significant Deficiency
  • 37571 2022-005
    Significant Deficiency
  • 37572 2022-006
    Significant Deficiency
  • 37573 2022-005
    Significant Deficiency
  • 37574 2022-006
    Significant Deficiency
  • 37575 2022-007
    Significant Deficiency
  • 614003 2022-001
    Material Weakness
  • 614004 2022-002
    Significant Deficiency
  • 614005 2022-003
    Material Weakness Repeat
  • 614006 2022-004
    Material Weakness
  • 614007 2022-005
    Significant Deficiency
  • 614008 2022-006
    Significant Deficiency
  • 614009 2022-005
    Significant Deficiency
  • 614010 2022-006
    Significant Deficiency
  • 614011 2022-005
    Significant Deficiency
  • 614012 2022-006
    Significant Deficiency
  • 614014 2022-006
    Significant Deficiency
  • 614015 2022-005
    Significant Deficiency
  • 614016 2022-006
    Significant Deficiency
  • 614017 2022-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.239 Home Investment Partnerships Program $141.16M
21.027 Coronavirus State and Local Fiscal Recovery Funds $90.35M
84.425 Education Stabilization Fund $52.13M
21.019 Coronavirus Relief Fund $37.76M
84.010 Title I Grants to Local Educational Agencies $32.74M
10.555 National School Lunch Program $29.43M
14.267 Continuum of Care Program $29.00M
21.023 Emergency Rental Assistance Program $23.84M
84.027 Special Education_grants to States $19.37M
14.231 Emergency Solutions Grant Program $15.08M
97.067 Homeland Security Grant Program $10.22M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4.43M
14.218 Community Development Block Grants/entitlement Grants $3.44M
84.367 Improving Teacher Quality State Grants $3.14M
14.889 Choice Neighborhoods Implementation Grants $2.50M
32.009 Emergency Connectivity Fund Program $2.42M
84.365 English Language Acquisition State Grants $2.15M
97.083 Staffing for Adequate Fire and Emergency Response (safer) $2.14M
66.443 Reducing Lead in Drinking Water (sdwa 1459b) $1.91M
84.424 Student Support and Academic Enrichment Program $1.53M
93.053 Nutrition Services Incentive Program $1.46M
84.048 Career and Technical Education -- Basic Grants to States $1.29M
10.559 Summer Food Service Program for Children $1.15M
14.905 Lead Hazard Reduction Demonstration Grant Program $875,418
84.287 Twenty-First Century Community Learning Centers $798,800
84.173 Special Education_preschool Grants $705,763
10.582 Fresh Fruit and Vegetable Program $589,666
84.002 Adult Education - Basic Grants to States $493,394
93.079 Cooperative Agreements to Promote Adolescent Health Through School-Based Hiv/std Prevention and School-Based Surveillance $461,145
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $434,221
16.034 Coronavirus Emergency Supplemental Funding Program $387,065
20.616 National Priority Safety Programs $330,000
16.738 Edward Byrne Memorial Justice Assistance Grant Program $327,657
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $327,115
97.111 Regional Catastrophic Preparedness Grant Program (rcpgp) $230,558
16.741 Dna Backlog Reduction Program $228,189
14.241 Housing Opportunities for Persons with Aids $198,525
94.016 Senior Companion Program $180,387
14.401 Fair Housing Assistance Program_state and Local $179,360
47.076 Education and Human Resources $178,788
14.248 Community Development Block Grants_section 108 Loan Guarantees $151,694
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $139,975
97.042 Emergency Management Performance Grants $136,689
94.002 Retired and Senior Volunteer Program $134,065
84.196 Education for Homeless Children and Youth $133,025
93.052 National Family Caregiver Support, Title Iii, Part E $128,466
97.106 Securing the Cities Program $117,605
16.588 Violence Against Women Formula Grants $116,980
16.820 Postconviction Testing of Dna Evidence to Exonerate the Innocent $115,958
16.838 Comprehensive Opioid Abuse Site-Based Program $99,654
10.649 Pandemic Ebt Administrative Costs $82,855
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $77,511
97.047 Pre-Disaster Mitigation $75,000
45.149 Promotion of the Humanities_division of Preservation and Access $64,064
12.900 Language Grant Program $62,353
45.301 Museums for America $58,423
16.817 Byrne Criminal Justice Innovation Program $54,978
97.044 Assistance to Firefighters Grant $31,952
97.039 Hazard Mitigation Grant $29,550
14.261 Homeless Management Information Systems Technical Assistance $25,333
45.024 Promotion of the Arts_grants to Organizations and Individuals $22,500
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $22,337
10.331 Food Insecurity Nutrition Incentive Grants Program $18,005
16.745 Criminal and Juvenile Justice and Mental Health Collaboration Program $17,540
16.015 Missing Alzheimer's Disease Patient Assistance Program $12,177
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $9,776
16.833 National Sexual Assault Kit Initiative $9,758
14.U00 Brownsfields Economic Development Initiative $7,379
20.600 State and Community Highway Safety $5,364
93.763 Alzheimer?s Disease Initiative: Specialized Supportive Services Project (adi-Sss) Thru Prevention and Public Health Funds (pphf) $2,777
84.411 Investing in Innovation (i3) Fund $1,836
20.205 Highway Planning and Construction $1,634
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $1,529