Finding 971405 (2022-006)

Federal Program Community Programs to Improve Minority Health - 93.137, Contract 1 CPIMP211290-01-00 Criteria Each entity that passes federal funds to a subrecipient must evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring related to the subaward and monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes per 2 CFR, Section 200.332(d). Condition The City did not perform a risk assessment or any additional monitoring of subrecipients beyond reviewing requests for payment. Cause This is a new grant for the City in 2022 and there was turnover in the grant director position during the year. Effect If subrecipient monitoring procedures were performed, the City would be able to ensure that funds were used to carry out the subaward for the intended purpose. Questioned Costs None. Context The City was awarded a grant to be used for improving minority health. To carry out part of the grant programs, the City has contracted with subrecipients’ organizations. The City has a process where all applications for reimbursement from the subrecipients is reviewed with proper documentation before approval for payment. The City does not perform a risk assessment of the subrecipient agencies nor any further monitoring such as site visits. Repeat Finding Yes. Recommendation We recommend that the City continue developing standard operating procedures for subrecipient monitoring of grant activities. This is especially important for grants handled outside the community development office. Management Response See corrective action plan included in this report package.