FAC Explorer

Finding 626242 (2022-008)

Material Weakness
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-05-01
Audit: 42414
Organization: County of Solano (CA)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The County failed to include required federal award identification elements in subrecipient agreements and lacked documented policies for risk assessment and monitoring.
  • Impacted Requirements: Noncompliance with 2 CFR 200.331, which mandates proper evaluation and monitoring of subrecipients to ensure compliance with federal regulations.
  • Recommended Follow-up: The County should create and implement documented policies for subrecipient monitoring, including risk assessments and contract reviews.

Finding Text

Program: Emergency Rental Assistance Program Assistance Listing No.: 21.023 Federal Agency: U.S. Department of the Treasury Passed-through: n/a ? direct award Award Number and Year: Not Applicable, 2021/2022 Compliance Requirement: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Criteria: 2 CFR 200.331(a) establishes the required elements that the pass-through entity (County) must include in their subrecipient agreements. 2 CFR 200.331(b) establishes the requirement that the pass-through entity must evaluate the risk of noncompliance with Federal statutes, regulations, and terms and conditions of the program for each subaward for the purpose of determining the appropriate subrecipient monitoring activities. 2 CFR 200.331(d) and 2 CFR 200.331(e) establishes the requirement that the pass-through entity must monitor the activities of each subrecipient of program funds to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward and achieves performance goals. 2 CFR 200.331(d) requires that the monitoring activities must include: 1. Reviewing of financial and performance reports as required by the pass-through entity. 2. 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 other means. 3. Issuing a management decision for audit findings pertaining to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521 Management decision. 2 CRF 200.331(f) establishes the requirement for the pass-through entity to verify whether the subrecipient is subject to a single audit when the subrecipient?s expenditures are expected to exceed the threshold set forth in 2 CRF 200.501. Condition: In 1 out of 1 instance selected, we found that the subrecipient agreement did not contain the federal award identification elements required to be communicated by the County. We found that the County did not have documented policies or procedures for the evaluation of the subrecipient?s risk of noncompliance with program requirements prior to awarding the subrecipient contract. We also found that the County did not have documented monitoring procedures to be followed based on the assessed level of risk of noncompliance. Furthermore, the County did not have documented procedures to verify whether the subrecipient was subject to a single audit. As a result, we found that in 1 out of 1 instance selected, a documented assessment of the subrecipient?s risk of noncompliance was not performed. In this same instance, a documented review of whether the subrecipient was subject to a single audit was also not performed. Cause: The County did not have documented policies and procedures over subrecipient monitoring to ensure that the required risk assessments and monitoring procedures were performed. The County?s subrecipient contracting procedures also did not require the inclusion of the required elements. Effect: The County did not include all the required elements in their subawards and did not perform appropriate monitoring procedures over the subrecipients. Questioned Costs: None noted. Context/Sampling: We selected 100% of the County?s subrecipients of the program. $6,177,719 was paid to the subrecipient during the fiscal year. Repeat Finding from Prior Year: No. Recommendation: We recommend that the County establish documented policies and procedures over subrecipient monitoring, including a documented risk assessment, monitoring procedures, and contract reviews. Views of Responsible Officials: Management agrees with the finding. See separate corrective action plan.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 49775 2022-003
    Material Weakness Repeat
  • 49776 2022-004
    Material Weakness Repeat
  • 49777 2022-003
    Material Weakness Repeat
  • 49778 2022-004
    Material Weakness Repeat
  • 49779 2022-011
    Material Weakness
  • 49780 2022-011
    Material Weakness
  • 49781 2022-011
    Material Weakness
  • 49782 2022-011
    Material Weakness
  • 49783 2022-011
    Material Weakness
  • 49784 2022-011
    Material Weakness
  • 49785 2022-011
    Material Weakness
  • 49786 2022-011
    Material Weakness
  • 49787 2022-009
    Material Weakness
  • 49788 2022-010
    Material Weakness
  • 49789 2022-009
    Material Weakness
  • 49790 2022-010
    Material Weakness
  • 49791 2022-009
    Material Weakness
  • 49792 2022-010
    Material Weakness
  • 49793 2022-009
    Material Weakness
  • 49794 2022-010
    Material Weakness
  • 49795 2022-005
    Material Weakness
  • 49796 2022-005
    Material Weakness
  • 49797 2022-005
    Material Weakness
  • 49798 2022-006
    Significant Deficiency
  • 49799 2022-007
    Material Weakness
  • 49800 2022-008
    Material Weakness
  • 626217 2022-003
    Material Weakness Repeat
  • 626218 2022-004
    Material Weakness Repeat
  • 626219 2022-003
    Material Weakness Repeat
  • 626220 2022-004
    Material Weakness Repeat
  • 626221 2022-011
    Material Weakness
  • 626222 2022-011
    Material Weakness
  • 626223 2022-011
    Material Weakness
  • 626224 2022-011
    Material Weakness
  • 626225 2022-011
    Material Weakness
  • 626226 2022-011
    Material Weakness
  • 626227 2022-011
    Material Weakness
  • 626228 2022-011
    Material Weakness
  • 626229 2022-009
    Material Weakness
  • 626230 2022-010
    Material Weakness
  • 626231 2022-009
    Material Weakness
  • 626232 2022-010
    Material Weakness
  • 626233 2022-009
    Material Weakness
  • 626234 2022-010
    Material Weakness
  • 626235 2022-009
    Material Weakness
  • 626236 2022-010
    Material Weakness
  • 626237 2022-005
    Material Weakness
  • 626238 2022-005
    Material Weakness
  • 626239 2022-005
    Material Weakness
  • 626240 2022-006
    Significant Deficiency
  • 626241 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $19.52M
21.023 Covid-19 Emergency Rental Assistance Program $11.44M
93.563 Child Support Enforcement $8.72M
93.658 Foster Care_title IV-E $7.18M
93.659 Adoption Assistance $5.10M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $2.89M
93.268 Immunization Cooperative Agreements $2.84M
14.871 Section 8 Housing Choice Vouchers $2.72M
10.557 Special Supplemental Nutrition Program for Women, Infants, and Children $2.63M
93.224 Covid-19 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $2.50M
93.224 Consolidated Health Centers (community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care) $1.74M
17.278 Wia Dislocated Worker Formula Grants $1.03M
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $921,220
17.258 Wia Adult Program $898,929
20.106 Airport Improvement Program $833,148
93.870 Maternal, Infant and Early Childhood Home Visiting Grant $827,627
10.025 Plant and Animal Disease, Pest Control, and Animal Care $750,970
93.667 Social Services Block Grant $686,112
93.090 Guardianship Assistance $664,682
16.575 Crime Victim Assistance $609,400
16.738 Edward Byrne Memorial Justice Assistance Grant Program $492,601
93.045 Covid-19 Special Programs for the Aging_title Iii, Part C_nutrition Services $485,349
93.958 Block Grants for Community Mental Health Services $431,731
93.498 Covid-19 Provider Relief Fund $407,800
93.994 Maternal and Child Health Services Block Grant to the States $348,416
93.052 National Family Caregiver Support, Title Iii, Part E $319,069
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $300,644
93.069 Public Health Emergency Preparedness $290,538
93.556 Promoting Safe and Stable Families $287,193
16.034 Covid-19 Coronavirus Emergency Supplemental Funding Program $259,416
93.053 Nutrition Services Incentive Program $258,124
20.608 Minimum Penalties for Repeat Offenders for Driving While Intoxicated $257,410
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $242,561
20.616 National Priority Safety Programs $224,999
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $214,994
20.205 Highway Planning and Construction $198,778
93.889 National Bioterrorism Hospital Preparedness Program $188,888
93.917 Hiv Care Formula Grants $187,925
93.558 Temporary Assistance for Needy Families $186,959
93.527 Affordable Care Act (aca) Grants for New and Expanded Services Under the Health Center Program $181,400
16.606 State Criminal Alien Assistance Program $175,000
93.526 Affordable Care Act (aca) Grants for Capital Development in Health Centers $157,171
93.645 Stephanie Tubbs Jones Child Welfare Services Program $149,297
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $131,777
93.052 Covid-19 National Family Caregiver Support, Title Iii, Part E $122,881
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $117,086
93.940 Hiv Prevention Activities_health Department Based $115,375
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $113,350
97.067 Homeland Security Grant Program $112,266
17.277 Workforce Investment Act (wia) National Emergency Grants $110,652
97.042 Emergency Management Performance Grants $107,500
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $82,897
59.037 Small Business Development Centers $76,382
93.042 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $68,778
93.150 Projects for Assistance in Transition From Homelessness (path) $65,432
14.879 Mainstream Vouchers $48,914
14.896 Family Self-Sufficiency Program $42,176
93.566 Refugee and Entrant Assistance_state Administered Programs $42,101
93.590 Community-Based Child Abuse Prevention Grants $33,596
20.106 Covid-19 Airport Improvement Program $32,000
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $31,297
93.043 Special Programs for the Aging_title Iii, Part D_disease Prevention and Health Promotion Services $29,825
93.044 Covid-19 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $29,520
16.U03 2022 Domestic Cannabis Eradication Suppression Program $21,913
93.197 Childhood Lead Poisoning Prevention Projects_state and Local Childhood Lead Poisoning Prevention and Surveillance of Blood Lead Levels in Children $21,556
17.259 Wia Youth Activities $21,176
16.U01 Safe Streets Violent Crimes Initiative $16,393
93.354 Covid-19 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $13,986
16.922 Equitable Sharing Program $8,662
16.U02 2021 Domestic Cannabis Eradication Suppression Program $8,627
93.041 Special Programs for the Aging_title Vii, Chapter 3_programs for Prevention of Elder Abuse, Neglect, and Exploitation $8,555
93.603 Adoption Incentive Payments $5,252
16.742 Paul Coverdell Forensic Sciences Improvement Grant Program $4,003
93.042 Covid-19 Special Programs for the Aging_title Vii, Chapter 2_long Term Care Ombudsman Services for Older Individuals $3,423
10.555 National School Lunch Program $2,937