FAC Explorer

Finding 637994 (2022-007)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2022
Accepted
2023-06-29
Audit: 56719
Organization: Wabanaki Health and Wellness (ME)
Auditor: Wipfli LLP

AI Summary

  • Core Issue: The Organization failed to meet any subrecipient monitoring and management requirements as outlined in 2 CFR Part 200.332, leading to a material weakness and noncompliance.
  • Impacted Requirements: Key requirements include proper identification of subawards, evaluation of subrecipient risk, and monitoring of financial and performance reports.
  • Recommended Follow-Up: Management should receive training on subrecipient requirements and implement a compliance monitoring plan to address identified weaknesses.

Finding Text

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; 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; 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. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. 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 pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. 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. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. 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. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 61526 2022-001
    Material Weakness Repeat
  • 61527 2022-002
    Material Weakness Repeat
  • 61528 2022-003
    Significant Deficiency Repeat
  • 61529 2022-006
    Significant Deficiency Repeat
  • 61530 2022-008
    Significant Deficiency Repeat
  • 61531 2022-001
    Material Weakness Repeat
  • 61532 2022-002
    Material Weakness Repeat
  • 61533 2022-003
    Significant Deficiency Repeat
  • 61534 2022-006
    Significant Deficiency Repeat
  • 61535 2022-007
    Material Weakness Repeat
  • 61536 2022-008
    Significant Deficiency Repeat
  • 61537 2022-009
    Significant Deficiency Repeat
  • 61538 2022-001
    Material Weakness Repeat
  • 61539 2022-002
    Material Weakness Repeat
  • 61540 2022-003
    Significant Deficiency Repeat
  • 61541 2022-006
    Significant Deficiency Repeat
  • 61542 2022-008
    Significant Deficiency Repeat
  • 61543 2022-001
    Material Weakness Repeat
  • 61544 2022-002
    Material Weakness Repeat
  • 61545 2022-003
    Significant Deficiency Repeat
  • 61546 2022-006
    Significant Deficiency Repeat
  • 61547 2022-008
    Significant Deficiency Repeat
  • 61548 2022-001
    Material Weakness Repeat
  • 61549 2022-002
    Material Weakness Repeat
  • 61550 2022-003
    Significant Deficiency Repeat
  • 61551 2022-006
    Significant Deficiency Repeat
  • 61552 2022-007
    Material Weakness Repeat
  • 61553 2022-008
    Significant Deficiency Repeat
  • 61554 2022-009
    Significant Deficiency Repeat
  • 61555 2022-001
    Material Weakness Repeat
  • 61556 2022-002
    Material Weakness Repeat
  • 61557 2022-003
    Significant Deficiency Repeat
  • 61558 2022-006
    Significant Deficiency Repeat
  • 61559 2022-007
    Material Weakness Repeat
  • 61560 2022-008
    Significant Deficiency Repeat
  • 61561 2022-009
    Significant Deficiency Repeat
  • 61562 2022-001
    Material Weakness Repeat
  • 61563 2022-002
    Material Weakness Repeat
  • 61564 2022-003
    Significant Deficiency Repeat
  • 61565 2022-006
    Significant Deficiency Repeat
  • 61566 2022-008
    Significant Deficiency Repeat
  • 61567 2022-009
    Significant Deficiency Repeat
  • 637968 2022-001
    Material Weakness Repeat
  • 637969 2022-002
    Material Weakness Repeat
  • 637970 2022-003
    Significant Deficiency Repeat
  • 637971 2022-006
    Significant Deficiency Repeat
  • 637972 2022-008
    Significant Deficiency Repeat
  • 637973 2022-001
    Material Weakness Repeat
  • 637974 2022-002
    Material Weakness Repeat
  • 637975 2022-003
    Significant Deficiency Repeat
  • 637976 2022-006
    Significant Deficiency Repeat
  • 637977 2022-007
    Material Weakness Repeat
  • 637978 2022-008
    Significant Deficiency Repeat
  • 637979 2022-009
    Significant Deficiency Repeat
  • 637980 2022-001
    Material Weakness Repeat
  • 637981 2022-002
    Material Weakness Repeat
  • 637982 2022-003
    Significant Deficiency Repeat
  • 637983 2022-006
    Significant Deficiency Repeat
  • 637984 2022-008
    Significant Deficiency Repeat
  • 637985 2022-001
    Material Weakness Repeat
  • 637986 2022-002
    Material Weakness Repeat
  • 637987 2022-003
    Significant Deficiency Repeat
  • 637988 2022-006
    Significant Deficiency Repeat
  • 637989 2022-008
    Significant Deficiency Repeat
  • 637990 2022-001
    Material Weakness Repeat
  • 637991 2022-002
    Material Weakness Repeat
  • 637992 2022-003
    Significant Deficiency Repeat
  • 637993 2022-006
    Significant Deficiency Repeat
  • 637995 2022-008
    Significant Deficiency Repeat
  • 637996 2022-009
    Significant Deficiency Repeat
  • 637997 2022-001
    Material Weakness Repeat
  • 637998 2022-002
    Material Weakness Repeat
  • 637999 2022-003
    Significant Deficiency Repeat
  • 638000 2022-006
    Significant Deficiency Repeat
  • 638001 2022-007
    Material Weakness Repeat
  • 638002 2022-008
    Significant Deficiency Repeat
  • 638003 2022-009
    Significant Deficiency Repeat
  • 638004 2022-001
    Material Weakness Repeat
  • 638005 2022-002
    Material Weakness Repeat
  • 638006 2022-003
    Significant Deficiency Repeat
  • 638007 2022-006
    Significant Deficiency Repeat
  • 638008 2022-008
    Significant Deficiency Repeat
  • 638009 2022-009
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $2.06M
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $894,088
93.933 Demonstration Projects for Indian Health $754,569
93.011 National Organizations of State and Local Officials $692,226
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $574,127
93.859 Biomedical Research and Research Training $439,613
93.772 Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement $319,573
10.225 Community Food Projects $207,726
93.137 Community Programs to Improve Minority Health Grant Program $201,707
93.762 A Comprehensive Approach to Good Health and Wellness in Indian County ? Financed Solely by Prevention and Public Health $189,184
15.144 Indian Child Welfare Act_title II Grants $148,473
93.872 Tribal Maternal, Infant, and Early Childhood Home Visiting $136,305
66.306 Environmental Justice Collaborative Problem-Solving Cooperative Agreement Program $113,481
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $93,023
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $78,800
93.558 Temporary Assistance for Needy Families $65,632
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $55,054
93.958 Block Grants for Community Mental Health Services $50,059
93.493 Community Project Funding/congressionally Directed Spending Construction $44,560
21.027 Coronavirus State and Local Fiscal Recovery Funds $43,695
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $23,357
93.587 Promote the Survival and Continuing Vitality of Native American Languages $20,200
93.268 Immunization Cooperative Agreements $15,211
93.788 Opioid Str $7,500
93.959 Block Grants for Prevention and Treatment of Substance Abuse $5,750