Finding Text
Federal Agency: Department of Health and Human Services
Federal Program: 93.137 Community Programs to Improve Minority Health Grant Program
Identification Number: 1 CPIMP211296-01-00
Requirement: Subrecipient Monitoring
Type of Finding: Material weakness in internal control over major program; Noncompliance
Criteria: Subaward agreements should include terms and conditions of the subaward, making the subrecipient aware of the award information required by Uniform Guidance Section 200.331(a) sufficient for the pass-through entity to comply with federal statutes, regulations and the terms and conditions of the award.
Condition: Subaward agreements do not make Uniform Guidance requirements and regulations clear. They also do not contain language that supports subrecipient classification.
Cause: Program management does not possess adequate knowledge of subrecipient monitoring requirements.
Effect: Failure to explicitly state federally-imposed requirements and regulations may result in noncompliance by the subrecipient and lead to federal inquiries of those charged with governance.
Context: Subrecipient agreements are titled “Memorandums of Understanding” instead of subaward agreements. The agreement with the one subrecipient does not state a dollar amount that is being passed-through over the course of the agreement. The terms and conditions do not explicitly mention the Uniform Guidance. The agreement makes references to both subcontractors and subrecipients, and never explicitly identifies the subrecipient as such. The other subrecipient agreement refers to the City of Frederick, Maryland as “the Sponsor”, not a pass-through entity and does not explicitly name the subrecipient as such. The agreement does not mention the Uniform Guidance.
Recommendation: Program management should revise subaward agreements to specifically note the requirements and regulations of the Uniform Guidance, as noted in Section 200.331(a).
Views of Responsible Official(s) and Planned Corrective Actions: See corrective action plan.