Finding Text
Criteria: Per 2 CFR § 200.332(a)(1), all pass-through entities must ensure that every subaward is clearly
identified to the subrecipient as a subaward and include federal award identifying information such as
the total amount of federal funds committed to the subrecipient by the pass-through entity, name of the
federal awarding agency, and assistance listing number and title. Condition: Communication with the subrecipient includes the grant name and total funds committed to the subrecipient, but it does not disclose the portion that is federal funds, the federal awarding agency, or the assistance listing number and title. Cause: Grant agreements with the subrecipient have not historically included this information and templates were used from prior years to prepare the latest agreements. Effect: The subrecipient was not aware that their award included federal funds, and so did not include it on their Schedule of Expenditures of Federal Awards. Management's Response: The identified deficiency relates to the Safe Routes to School (SRTS) funds (OBAG 2 funds) passed through via agreement with the San Mateo County Office of Education (SMCOE). As noted by the auditor, the agreement describes the funding source with the same language previously used in prior grant agreements. Specifically, on page 26, the existing grant agreement states: “C/CAG and SMCOE have a joint interest in ensuring that schools and community agencies effectively implement programs that enable them to use the Federal Surface Transportation Program and Congestion Mitigation & Air Quality Improvement (STP/CMAQ) Program funds productively on behalf of students and the community.” To improve the communication of the nature of the federal funding and associated requirements, C/CAG will ensure that future federal pass-through grant agreements include the following information and language: (1) The specific portion of funding that is federal funds, the Federal Awarding Agency, full funding amount and applicable Federal Project Number, listing number and title. (2) A portion of the funds included are federal funds, and the recipient is responsible for compliance with all relevant Federal requirements, including, but not limited to § 200.501 Audit
requirements and 2 CFR § 200.332 Requirements for pass-through entities.