Finding Text
Finding 2023-003 Significant Deficiency: Subrecipient Monitoring - Control
Finding
ALN 21.027: COVID-19: Coronavirus State and Local Fiscal Recovery Funds
Federal Agency: U.S. Department of the Treasury
Pass-through Entity: Illinois State Board of Education
Criteria Or Specific Requirement: Per 2 CFR 200.332(a)(1), the Project is
responsible for inform subrecipients of the Federal award identifiers including but not
limited to award date, period of performance, Federal awarding agency, Assistance
Listing Number and program name. Per 2 CFR 200.332(d), the Project is responsible
for reviewing financial and performance reports inclusive of single audit reports. The
monitoring policy should include an initial evaluation of the risk of noncompliance to
determine the appropriate level of monitoring required related to the subaward and
ensure the continued monitoring of the subrecipients inclusive of review of
subrecipients’ single audit reports, when applicable.
Condition: We noted that management did not provide subrecipients with all required
information and the review of subrecipients’ single audit reports was not a part of their
monitoring procedures.
Cause: Management does not have an internal control process in place to ensure proper
subrecipient monitoring.
Effect: Failure to communicate all required federal award identification may result in
subrecipients not complying with federal requirements of program funds.
Questioned Costs: None
Context: The Project did complete a risk assessment of subrecipients and completed
monitoring of grant activity through monthly monitoring as well as mid-year reviews.
However, during the testing performed, we noted management did not retain evidence
of informing all subrecipients of all required information.
Identification As A Repeat Finding: N/A
Recommendation: We recommend that all subrecipient grant agreements are updated
to include all required identification set forth by 2 CFR 200.332(a)(1) and 2 CFR
200.332(d).
Views Of Responsible Officials And Planned Corrective Action: An adequate
subrecipient risk assessment policy will be put in place to evaluate and monitor
subrecipients. Southwest Organizing Project will provide subrecipients with all
required federal award identifiers. Management will ensure that federal award
identifiers are included in subrecipients grant agreements.