EIN: 146098221
UEI: WWJDEF3RNWT3
Data as of August 27, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 27, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 27, 2025 (334 days ago).
What is a management decision? →The Agency did not identify a subrecipient of the Coronavirus State and Local Fiscal Recovery Funds and applicable requirements at the time a subaward was made to another Organization. Criteria: Internal controls should be in place to ensure management identifies any subrecipients of Federal grants and has processes in place to notify and monitor the subrecipient. Cause: There were no procedures in place to determine if any grants were subawards to subrecipients. Effect: Because the terms and conditions of the subaward were not identified, the Agency may not have been able to comply with Federal statutes, regulations, and the terms and conditions of the Federal award. Recommendation: Procedures should be implemented to evaluate grant activity and contracts to make a determination of subrecipients or beneficiaries on all grant awards.
Show full finding ▾Hide full finding ▴U.S. DEPARTMENT OF TREASURY , SIGNIFICANT DEFICIENCY 2024-002 COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Identification of Federal Subaward Condition: The Agency did not identify a subrecipient of the Coronavirus State and Local Fiscal Recovery Funds and applicable requirements at the time a subaward was made to another Organization. Criteria: Internal controls should be in place to ensure management identifies any subrecipients of Federal grants and has processes in place to notify and monitor the subrecipient. Cause: There were no procedures in place to determine if any grants were subawards to subrecipients. Effect: Because the terms and conditions of the subaward were not identified, the Agency may not have been able to comply with Federal statutes, regulations, and the terms and conditions of the Federal award. Recommendation: Procedures should be implemented to evaluate grant activity and contracts to make a determination of subrecipients or beneficiaries on all grant awards.
Views of Responsible Officials and Planned Corrective Actions: We acknowledge the validity of this finding and offer the following explanation. While we recognized the Agency’s role as a subrecipient, we did not fully understand the guidelines for distinguishing between a “contractor” and a “subrecipient” when making a subaward to another organization. However, through a thorough discussion and assessment of the guidelines with the auditors, along with a joint review of the GSA-CX-1.8: Subrecipient and Contractor Determination Form, we have gained clarity on the proper process for making accurate determinations in future subawards. Corrective Action: For future grant awards, Agency staff will review the use of funds in accordance with federal guidelines to determine whether the recipient qualifies as a subrecipient or a contractor. Additionally, the Agency has taken steps to notify the organization of their subrecipient status and their obligation to conduct a Single Audit in compliance with Government Accounting Standards and Uniform Guidance requirements.
The Agency did not identify the subaward of the Coronavirus State and Local Fiscal Recovery Funds and applicable requirements at the time the subaward was made. Because of the failure to identify the subaward, the Agency was not able to comply with monitoring subrecipient activities to provide reasonable assurance that the subrecipient administered the subaward in compliance with the terms and conditions of the subaward in accordance with the Uniform Guidance. Criteria: Federal administration requires a pass-through entity (PTE) to identify the federal award and requirements to a subrecipient and to then monitor subrecipient activities. Cause: Since the Agency did not identify the subaward at time of contract, they did not complete subrecipient compliance requirements as required under the Uniform Guidance throughout the grant period. Effect: The Agency did not notify the subaward as identified in finding 2024-002, and therefore, was not following subrecipient monitoring requirements under the Uniform Guidance and the costs could potentially be disallowed. Recommendation: We recommend that any subrecipients are identified at time contracts are agreed upon and that the Agency ensures proper subrecipient notification and monitoring throughout the grant period for compliance with the Uniform Guidance.
Show full finding ▾Hide full finding ▴INSTANCE OF NONCOMPLIANCE 2024-003 COVID-19 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Subrecipient Monitoring Condition: The Agency did not identify the subaward of the Coronavirus State and Local Fiscal Recovery Funds and applicable requirements at the time the subaward was made. Because of the failure to identify the subaward, the Agency was not able to comply with monitoring subrecipient activities to provide reasonable assurance that the subrecipient administered the subaward in compliance with the terms and conditions of the subaward in accordance with the Uniform Guidance. Criteria: Federal administration requires a pass-through entity (PTE) to identify the federal award and requirements to a subrecipient and to then monitor subrecipient activities. Cause: Since the Agency did not identify the subaward at time of contract, they did not complete subrecipient compliance requirements as required under the Uniform Guidance throughout the grant period. Effect: The Agency did not notify the subaward as identified in finding 2024-002, and therefore, was not following subrecipient monitoring requirements under the Uniform Guidance and the costs could potentially be disallowed. Recommendation: We recommend that any subrecipients are identified at time contracts are agreed upon and that the Agency ensures proper subrecipient notification and monitoring throughout the grant period for compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions: We accept the validity of this finding for the same reasons stated above in finding 2024-002. We actively monitored the subrecipient’s management of the subaward through documentation and regular personal contact. However, because we did not recognize the organization as a subrecipient, we did not adhere to the proper subrecipient monitoring requirements outlined in the Uniform Guidance. Corrective Action: As noted above in the corrective action to finding 2024-002, we have notified the organization of their subrecipient status; the requirement to conduct a Single Audit of its administration of their subaward; and the need to provide the JCIDA with a copy of the organization’s most recent audited financial statements and federal Single Audit reports once completed, if they expended over $750,000 of federal awards. We will include these requirements in future subrecipient contracts.
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