Finding Text
Assistance Listing Number(s): 21.027
Name of Federal Program or Cluster: COVID-19 Coronavirus State and Local Fiscal Recovery Funds
Name of Federal Agency: Department of the Treasury
Name of Pass-through Entity: City of Madison, City of Sun Prairie, Wisconsin Department of Workforce
Development
Award Period: January 1, 2022 through December 31, 2022; September 22, 2021 through December 31,
2024; June 20, 2022 through June 30, 2025
Criteria or Specific Requirement: 2 CFR section 200.332(a) requires pass-through entities to ensure every
subaward is clearly identified to the subrecipient as a subaward and includes the required federal award
identification information, all requirements imposed by the pass-through entity on the subrecipient, any
additional requirements the pass-through entity imposes on the subrecipient, an indirect cost rate, a
requirement that the subrecipient permit the pass-through entity and auditors to have access to the
subrecipient’s records and financial statements, and appropriate terms and conditions concerning the
closeout of the subaward. 2 CFR section 200.332(b) requires the pass-through entity to evaluate each
subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions for
determining appropriate subrecipient monitoring. 2 CFR section 200.332(d) requires the pass-through
entity to monitor the activities of the subrecipient to ensure that the subaward is used for authorized
purposes, in compliance with federal statutes, regulations, and the terms and conditions of the subaward,
and that the subaward performance goals are achieved. 2 CFR section 200.332(f) requires the passthrough
entity to verify that every subrecipient is audited as required by the Uniform Guidance when it is
expected that the subrecipient’s federal awards expended during the respective fiscal year equaled or
exceeded $750,000.
Condition and Context: No supporting documentation was provided for the three subrecipients. No
subaward agreements included all required information and none were executed and signed. No risk
assessments were performed and documented. No monitoring procedures were performed other than
reviewing invoices to be paid. Per the draft subawards, quarterly site visits were to occur, but none were
performed and documented. There was no documentation of whether the 3 subrecipients were expected
to/are being audited per the Uniform Guidance.
Cause: Internal controls have not been designed, implemented, and documented in written procedures.
Internal controls are not designed or implemented to ensure subrecipient agreements include the required
information, to perform risk assessments, to establish monitoring procedures based on risks, to ensure
monitoring takes placed as planned, and to verify whether subrecipients that expended $750,000 or more
in federal awards is audited in accordance with the Uniform Guidance.
Effect or Potential Effect: Questioned costs may be disallowed and requested to be repaid.
Questioned Costs: $298,051; amount per GL paid to three subrecipients during the fiscal year.
Repeat Finding: No.
Recommendation: Procedures for subrecipient monitoring to meet federal statutes, regulations, and terms
and conditions of the awards should be developed and documented. Internal controls should be designed, implemented, and documented within the subrecipient monitoring procedures to ensure
compliance with 2 CFR section 200.332. Subrecipient monitoring activities should be performed and
documented.
Views of Responsible Officials: Boys and Girls Club of Dane County, Inc. agrees with the finding and is
implementing written procedures.