County of WashtenawLocal Government

Lack of Subrecipient Monitoring Auditor Description of Criteria, Condition, and Effect: Under 2 CFR Part 200.332(e), the pass through-entity must monitor the activities of a subrecipient as necessary to ensure that the subrecipient complies with Federal statutes, regulations, and the terms and conditions of the subaward. The pass-through entity is responsible for monitoring the overall performance of a subrecipient to ensure that the goals and objectives of the subaward are achieved. The County performed financial monitoring procedures during the year and obtained and reviewed subrecipient single audit reports from those subrecipients who were required to have single audits performed under 2 CFR 200 Subpart F. However, the County could not provide evidence that programmatic or performance monitoring to ensure that the stated goals and objectives of the subaward program were achieved during the year, and as such did not comply with all necessary subrecipient monitoring requirements during the year as required in 2 CFR Part 200.332(e). The County did not follow all federal requirements for subrecipient monitoring and as a result has not completed all monitoring requirements for pass-through entities. Auditor Recommendation: We recommend that the County review its procedures for subrecipient monitoring to ensure compliance with Uniform Guidance. In the past, the County has had established procedures which included desk reviews and documented program monitoring of subrecipient programs, and it appears that not all of those procedures have remained in place due to staff turnover. The County should review, update, and implement procedures to ensure that those required elements of internal control are carried out by the responsible County department. Corrective Action: The Office of Community and Economic Development will implement a subrecipient monitoring policy specific to grants and operations including a schedule of monitoring and risk assessment. OCED program and finance staff will undergo training specific to subrecipient monitoring to ensure alignment in policies across programs. The OCED Finance and Operations Division Administrator will lead subrecipient monitoring activities and will coordinate as necessary with other OCED department division administrators to develop a monitoring schedule and communication plan for subrecipients. Washtenaw County Finance will assist in developing this subrecipient monitoring policy and will perform an overall review of all subrecipient monitoring to ensure compliance and consistency across departments and programs. Responsible Person: Chief Financial Officer Anticipated Completion Date: December 2025

Finding: 2023-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The County did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance. As a result, the County did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the County review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: The County will ensure that its procedures for FFATA reporting on all required grants are updated to ensure future compliance with this requirement. Responsible Person: Ellis Johnson II, Finance and Operations Manager (Office of Community and Economic Development) Anticipated Completion Date: December 31, 2024

GSA_MIGRATION