Finding Text
Criteria or specific requirement: According to ?200.332 Requirements for pass-through entities of 2 CFR Part 200, all pass-through entities must 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. In addition, the pass-through entity must 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; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: ? Reviewing financial and performance reports required by the pass-through entity. ? Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. ? Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management Decision. Condition: We noted the Organization is not in compliance with requirements related to the subrecipient monitoring of grants. Questioned costs: None Context: During our testing, we noted the following exceptions: ? The Organization lacked a process to review the audits of subrecipients that would allow the Organization to identify any potential deficiencies that would require follow-up. ? The Organization lacked a process to complete a risk assessment that would allow the Organization to 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. Cause: The Organization does not have internal controls in place to ensure compliance with Federal regulations or the terms and conditions of the Federal award. Effect: The lack of internal controls over this compliance requirement provides an opportunity for noncompliance. Noncompliance results in possible Federal funds provided to ineligible subrecipients. Repeat Finding: Yes ? 2021-004 Recommendation: We recommend that the Organization create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants. Views of responsible officials: The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have since followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors and one as a subrecipient which is described below: ? Union County General Hospital (UCGH): Both ROAMS and UCGH see this relationship as a contractor. The stipend pays for a Tele-OB room in their facility and the budget even lists rent as part of the reason for the stipend. The stipend per the MoU also supports their participation in the monthly Governing Council meetings, data collection, IT support for the program implementation and decision making. ? Questa Health Center/Presbyterian Medical Services (Questa): Both ROAMS and Questa see this relationship as a contractor. The stipend pays for an OB room in their facility and is even listed as rent in the stipend budget. The stipend per the MoU also supports their participation in the monthly Governing Council and decision making. ? UNM Envision (UNM): UNM declared a portion of their stipend over the three-year period they received as subrecipient. They declared $39,635 as subrecipient and they received a total of $68,000 from ROAMS. ROAMS always saw the relationship as a contractor and not a subrecipient and we do not understand why they have declared a portion of their stipend as subrecipient. UNM was not an essential grant partner, joined in year two to assist with data review, participated in the Governing Council, and ROAMS has a data evaluation agreement with UNM that we understood as a contract. This different understanding of the relationships highlights the audit finding that the type of relationship should be agreed upon upfront. ? Miners Colfax Medical Center (MCMC): sees themselves as a subrecipient and we agree. They are a state hospital and the other Labor and Delivery hospital in the ROAMS grant, and like Holy Cross Medical Center have a very high data reporting burden and serve as the home for the patients. The Memorandum of Agreement signed by all Network partners outlines their obligations in section IV Provision of Services and VI Records and Information (a. b. and c.). As we have investigated the monitoring of subrecipients verses a contractor, we have found that the same follow up is necessary, as long as the subrecipient receives less than $750,000 in federal funds in a year, which is the case for MCMC. Our procedures for paying the stipend for both the contractors and one subrecipient (MCMC), have been attendance at the monthly Governing Council meetings, and deliverables from data collection, to IT support and meetings, workflow meetings, and clinical meetings. Reminders of deliverables that are pending are in the monthly Governing Council notes as is the attendance. ROAMS and the network partners were very clear in written documents and practice that the quarterly stipend payment was linked to participation and deliverables. We can provide you with monthly Governing Council notes to show this. A draft policy is in the works that will have the network partners formally declare their relationship as contractor or subrecipient and outline the monitoring of subrecipients. From our research we do not see the subrecipient monitoring being significantly different from a contractor unless the $750,000 threshold is met. The ROAMS grant did not clarify with the Network partners that receive $20,000 yearly stipends whether they were subrecipients or contractors, but instead assumed everyone was a contractor. We agree to this as a finding. We have followed up with the stipend partners and all but one has declared their stipends as contracts. ROAMS agrees with the classification of three as contractors. The ROAMS Director will request from the entities the audits for the CFO review to review for deficiencies on an annual basis.