Finding 946416 (2022-002)

Finding 2022-002 – Subrecipient Monitoring Department of Health and Human Services Passed through Pennsylvania Department of Human Services Foster Care – Title IV-E – ALN 93.658 Subrecipient Monitoring Condition: The County appropriately notified the subrecipients of the federal award identification and performed a risk assessment; however, the County did not monitor ten of the twelve subrecipients during the year to ensure compliance with federal statutes, regulations, and the terms and conditions of the subaward. Criteria: The Pennsylvania Department of Human Services (PA DHS) and 2 CFR section 200.332 require pass-through entities to ensure that the award is clearly identified to the subrecipient as a subaward and includes information at the time of the subaward regarding 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 and the terms and conditions of the federal award, any additional requirements that the pass-through entity imposes on the subrecipient, and 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. Additionally, the pass-through entity is required to evaluate each subrecipient’s risk of noncompliance, monitoring 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 verify that every subrecipient is audited as required by Subpart F, as necessary. It is the County’s policy, as part of the monitoring process, that each subrecipient of these federal awards be monitored annually. Cause: The County has established formal subrecipient monitoring policies. However, due to staffing issues, the County’s internal control process over subrecipient monitoring was not effective. Effect: A failure to monitor subrecipients’ compliance with relevant federal requirements could result in noncompliance with the terms and conditions of the subawards. Questioned Costs: Unknown. Identification as a Repeat Finding: This is not a repeat finding from the prior audit. Recommendation: We recommend that the County ensure adherence to the monitoring policy related to subrecipients and that these subrecipients be monitored on an annual basis in accordance with the policy. Management’s Response: Management agrees with this finding. See separate Corrective Action Plan.