Finding Text
Assistance Listing, Federal Agency, and Program Name - 84.425G, U.S. Department of Education, Education Stabilization Fund - Reimagining Workforce Preparation Grants
Federal Award Identification Number and Year - N/A
Pass-through Entity - State of Michigan Department of Labor & Economic Opportunity
Finding Type - Significant deficiency
Repeat Finding - No
Criteria - The College should have a subrecipient monitoring policy and defined procedures to follow when identifying and assessing subrecipients in accordance with 2 CFR section 200.332.
Condition - The College does not have a subrecipient monitoring policy and did not perform risk assessment procedures before selecting the subrecipient for the grant.
Questioned Costs - N/A
Context - There was one subrecipient for this grant. The College was required to find a subrecipient and selected a similar organization that they collaborate with on other projects. The selected subrecipient meets with the College monthly and provides and submit quarterly reimbursement forms and performance data. This is also the College's first subrecipient agreement.
Cause and Effect - The College did not have a system or process in place to select a subrecipient using a risk analysis process. As a result, the subrecipient chosen may not have been eligible or at risk of providing timely or accurate performance and financial data.
Recommendation - We recommend the College develop a subrecipient policy with defined procedures in alignment with Uniform Guidance in the efect they have subrecipients in the future for this and other grants.
Views of Responsible Officals and Corrective Action Plan - The College will work to develop a subrecipient monitoring policy and subrecipient monitoring procedures, which would include the performing of a risk assessment, to ensure the policies and procedures are in alignment with other College policies while also adhering to federal regulations and best practices in grant management.