Northeast Missouri Area Agency on AgingNon-Profit

Subrecipient Monitoring Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires pass-through entities to oversee the activities of service providers with respect to provision of services, reporting, voluntary contributions, and coordination of services under 2 CFR 200.332. Condition: The Agency Board did not comply with the Uniform Guidance requirement to evaluate each subrecipient's risk of non-compliance and to monitor activities to ensure the federal award is used for authorized purposes. Questioned Costs: $0 Cause: The Agency's internal control did not effectively identify policies and procedures for monitoring subrecipients, and the Agency did not comply with federal requirements regarding subrecipient monitoring. The Agency experienced significant key employee turnover during the year. Effect: The Agency was not in compliance with Uniform Guidance 2 CFR 200.332. Recommendation: We recommend the Agency monitors its subrecipients regularly. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and in March 2023, the Agency hired a new Executive Director and in August 2023, a new Fiscal Officer. The new management team has implemented policies and procedures to comply with subrecipient monitoring requirements.

Written Uniform Guidance Policies and Procedures Federal Program: Department of Health and Human Services Federal Assistance Listing No. 93.044, 93.045, and 93.053 - Aging Cluster Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E - Cost Principals. Condition: The Agency did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0 Cause: The Agency's written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and adopted the appropriate policies and procedures in December 2023.

Criteria: Uniform Guidance requires pass-through entities to oversee the activities of service providers with respect to provision of services, reporting, voluntary contributions, and coordination of services under 2 CFR 200.332. Condition: The Agency did not comply with the Uniform Guidance requirement to evaluate each subrecipient’s risk of non-compliance and to monitor activities to ensure the federal award is used for authorized purposes. Questioned Costs: $0 Cause: There was significant key employee turnover during and subsequent to the fiscal year-end. Effect: The Agency was not in compliance with Uniform Guidance 2 CFR 200.332. Recommendation: We recommend the Agency monitors its subrecipients regularly. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and in March 2023, the Agency hired a new Executive Director and in August 2023, a new Fiscal Officer. The new management team has implemented policies and procedures to comply with subrecipient monitoring requirements.

Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E – Cost Principals. Condition: The Agency did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0 Cause: The Agency’s written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Employees of the Agency could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend the Agency draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and adopted the appropriate policies and procedures in December 2023.