Finding Text
U.S. Department of Health and Human Services Passed through Health Research &
Educational Trust (HRET), Federal Financial Assistance Listing #93.318, 87728, Protecting and
Improving Health Globally: Building and Strengthening Public Health Impact, Systems,
Capacity and Security
Subrecipient Monitoring
Material Weakness in Internal Control over Compliance and Material Noncompliance
Criteria: Uniform Guidance section 200.332 requires that pass‐ through entities ensure every
subaward includes certain information at the time of the subaward and the assistance listing
number is communicated at the time of disbursement to subrecipients. It also requires that
pass‐through entities 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.
Condition: The Organization did not provide all required provisions on the subrecipient
agreements. Additionally, the Organization was not reviewing audit requirements.
Cause: The Organization has not properly reviewed requirements relating to subrecipients.
Effect: Incomplete contract agreements with subrecipients could be entered into and/or there
could be ineffective monitoring.
Questioned Costs: None reported.
Context: A nonstatistical sample of 9 transactions of 49 were selected for testing of subrecipient
monitoring, which accounted for $141,611 of $583,403 of subrecipient monitoring
expenditures.
Repeat Finding from Prior Years: No
Recommendation: We recommend the Organization ensure proper documentation is
maintained on contract agreements with subrecipients.
Views of Responsible Officials: Management agrees with the finding.