CITY OF GENESEO, ILLINIOS

Finding 2019-004 Noncompliance with Subrecipient Award Requirements Federal Agency ? U.S. Department of Agriculture Pass-through Entity ? N/A Direct Award Program Name ? Rural Economic Development Loan and Grant Program CFDA # and Program Expenditures ? 10.854 ($1,000,000) Federal Award Numbers ? Not Provided Questioned Costs - None Criteria ? 2 CFR 200.331 states that all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes: (1) Federal Award Identification: (i) Subrecipient name (which must match the name associated with its unique entity identifier); (ii) Subrecipient's unique entity identifier; (iii) Federal Award Identification Number (FAIN); (iv) Federal Award Date (see ?200.39 Federal award date) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (vii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current obligation; (viii) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (ix) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (x) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xi) CFDA Number and Name; the pass-through entity must identify the dollar amount made available under each Federal award and the CFDA number at time of disbursement; (xii) Identification of whether the award is R&D; and (xiii) Indirect cost rate for the Federal award (including if the de minimis rate is charged per ?200.414 Indirect (F&A) costs). (2) All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; (3) Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; (4) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or, if no such rate exists, either a rate negotiated between the pass-through entity and the subrecipient (in compliance with this part), or a de minimis indirect cost rate as defined in ?200.414 Indirect (F&A) costs, paragraph (f); (5) A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and (6) Appropriate terms and conditions concerning closeout of the subaward. Condition ? Auditors noted the following during testing of subrecipient award documentation: ? Subaward documentation for subrecipients did not include the following required elements: Subrecipient's unique entity number, Federal Award Identification Number (FAIN), CFDA Number, requirements of the Federal award, and a requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements. Cause ? Management was not aware of the specific requirements for pass-through subaward documentation. Effect ? The City is not in compliance with Federal requirements. Recommendation ? Management should ensure that all required elements are included in subawards to subrecipients. View of Responsible Officials ? We agree with the finding and have developed a corrective action plan. B Compliance Finding None

Corrective Action Plan We will review the applicable Federal requirements and update our subrecipient agreement templates to ensure all applicable data elements are included. Person(s) Responsible: Jo Hollenkamp, City Administrator; Jamie Matthews, City Finance Director; Kathy Carroll-Duda, Mayor Timing for Implementation: June 30, 2020