Finding Text
Assistance Listing Number, Federal Agency, and Program Name - U.S. Department of Labor H-1B Job Training Grants (ALN 17.268) and WIA/WIOA Pilots, Demonstrations, and Research Projects Strengthening Community Colleges Training Grants (ALN 17.261). Federal Award Identification Number and Year - HG-35916-21-60-A-26 and MI-35900-21-60-A-26.
Pass-through Entity - None.
Finding Type - Significant deficiency.
Repeat Finding - No.
Criteria - A passthrough entity must: (a) Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal award identification: (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see the definition of Federal award date in § 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass through entity, and contact information for awarding official of the Pass through entity; (xii) Assistance Listings number and Title; the pass through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. (2 CFR 200.332(a)). In addition, 2 CFR 200.332(d) states grantees are required to "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.
Condition - The College had the following issues noted: (1) It did not include items (1)(ii) subrecipient's unique unique entity identifier and (1)(xi) Name of federal awarding agency, passthrough entity or contact information within their subrecipient agreement; (2) It was not monitoring the subrecipient budgets and performance plans to ensure objectives were met; and (3) It was not monitoring financial expenditures that were below planned thresholds.
Questioned Costs - None.
Context - There were 5 subrecipients for grant #17.268 and 6 subrecipients for grant #17.671. There was approval and review of expenditures submitted by all subrecipients on a timely basis. In addition, each subrecipient is required to complete and submit a quarterly narrative performance report which the College uses to prepare the quarterly narrative performance report submitted to the granting agency.
Cause and Effect - The College did not have a system in place to monitor actual performance and financial measures against the planned activity as outlined in the subrecipient and grant agreements. The College was also not documenting the results of site visits of the subrecipients.
Recommendation - The College should implement controls to have subrecipients track and report perfornance and financial for planned versus actual reporting on a monthly or quarterly basis. In addition, the College should complete a written report summarizing the results of each onsite visit to its subrecipients as required under Uniform Guidance.
Views of Responsible Officials and Corrective Action Plan - Management agrees with the finding. The College has implemented a new Grants Administration Guide which covered initial risk assessment, subrecipient determination, subaward agreements, monitoring subrecipients and subrecipient reimbursements. In addition, the College has developed monthly metric reports for planned vs. actual outcomes which is to be completed by each subrecipient. The College has also scheduled formal site visits with each subrecipient to cover Financial status, metric verification, narrative overview and participant records and evaluation. A tool has been developed to summarize each site visit with recommendations. A written report will be provided to the subrecipients after each site visit.