Finding Text
SUBRECIPIENT MONITORING
Program: AL 21.027 – COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Subrecipient Monitoring
Grant Number & Year: NA
Federal Grantor Agency: U.S. Department of the Treasury
Repeat Finding: No
Questioned Costs: $750,000 likely
Condition: The County lacked procedures to ensure that subrecipients documented their use of Federal awards appropriately.
Criteria: Per 2 CFR § 200.332 (January 1, 2022), all pass-through entities must monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purpose, in compliance with Federal Statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient.
Cause: There were not proper procedures in place for subrecipient monitoring.
Potential Effect: Without adequate supporting documentation and monitoring procedures, there is an increased risk that Federal Awards could be used for unallowable costs.
Recommendation: We recommend that the County improve procedures to monitor subrecipients, including reviewing detailed supporting documentation for expenses and following up with subrecipients to ensure that they correct errors noted. The County may also want to consider using only reimbursement basis grants, so the supporting documentation is received prior to payment to subrecipients. This would help prevent issues of obtaining documentation to support the payments.
Views of Officials: The County is aware of the above finding and has adjusted our procedures related to disbursing federal funds to subrecipients. We have changed to a cost reimbursement basis for disbursing the federal funds to subrecipients. We currently receive supporting documentation prior to payment.