Finding Text
Criteria or specific requirement: The Code of Federal Regulations, 2 CFR 200.332, states that nonfederal entities passing federal awards through to other entities are required to ensure that subawards to subrecipients include required federal award identification and detail of all compliance and other requirements for the federal award.
Condition: During our testing we noted that the Company did not include the federally required elements of the award in the subrecipient agreement.
Context: For 6 of the 9 subrecipients selected, the Company did not include in their agreements the required federal award information as outlined by 2 CFR 200.332.
Cause: Management was made aware of requirements during the award period and created addendums for agreements with subrecipients. For 6 of the 9 subrecipients selected, addendums with the conditions of the award were not created at the time of our review, and the required information was not provided to subrecipients.
Effect: The Company is not in compliance with subrecipient monitoring requirements as outlined by 2 CFR 200.332.
Recommendation: We recommend the Company to include all guidance under 2 CFR 200.332 in the agreements entered with subrecipients.
Views of responsible officials: There is no disagreement with the audit finding. The company has investigated why the information was not provided, and found the cause was an isolated incident, and the error of a former employee who has since been removed from the company. Measures have been put in place to ensure future compliance.