Finding Text
Federal Agency: Department of Agriculture, National Aeronautics and Space Administration, and
Department of Health and Human Services
Federal Program Title: Research and Development Cluster
Assistance Listing Number: 10.216, 43.008, and 93.433
Federal Award Identification Number: 2021388213586-2023, NNX15AP43A-2023, 90RTST0001-2023,
90RTEM0009-2023
Award Period: 7/1/22-6/30/23
Type of Finding: Significant Deficiency in Internal Control over Compliance; Compliance, Other Matters
Condition: The University did not obtain timely documentation for subrecipient monitoring and did not
include required information in the subrecipient subawards.
Criteria or specific requirement: Uniform Guidance (2 CFR section 200.331 (a)) requires all pass-through
entities ensure that every subaward is clearly identified to the subrecipient as a subaward and include
information to comply with Federal statutes, regulations, and the terms and conditions of the award. The
required information includes the subrecipient’s DUNS number, ALN and name, federal award date, and
further additional requirements. When some of this information is not available, the pass-through entity shall
provide the best information available to describe the Federal award. Uniform Grant Guidance (2 CFR
200.331(d)) requires nonfederal entities receiving Federal awards monitor the activities of the subrecipient
as necessary to ensure the subaward is used for authorized purposes, in compliance with compliance with
Federal statutes, regulations and the terms and conditions of the subaward and the performance goals are
achieved. Pass-through entity monitoring of the subrecipient must include: (1) reviewing financial reports
and performance reports required by the pass–through entity and (2) following up and ensuring the
subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided
to the subrecipient from the pass-through entity detected through audits, on site reviews and other means.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish
and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,
and program compliance requirements.
Context: During our testing of 6 subrecipients, we identified that 6 did not have timely documentation for
subrecipient monitoring. The University did not follow up when responses were not received from
subrecipients for the subrecipient monitoring process. Additionally, we identified 2 subrecipients did not
have the required information included in the subaward agreement.
Questioned costs: N/A
Cause: The University did not have an effective control in place to ensure subrecipient monitoring was
complete and timely.
Effect: Failure to monitor subaward may result in unauthorized uses of federal funds passed-through to
subrecipients.
Repeat finding: No
Recommendation: We recommend the University review its procedures for the subrecipient monitoring
process to ensure the reviews are completed timely and implement procedures necessary to ensure
information is included in the subrecipient award documents at the time of funding.
Views of responsible officials: Management agrees with the finding and has developed a plan to correct