ALIANZA NACIONAL DE CAMPESINAS, INC.

Finding 2021 ? 001: Requirements for pass-through entities FEDERAL PROGRAM: ASSISTANCE LISTING NUMBER # 93.011 Criteria: As noted in 2 CFR 200.332, all pass-through entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes among other required information, to include the items below: ? Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement. ? 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 Condition: Alianza did not comply with some of the pass-through entities? requirements. Cause: While Alianza was aware of a majority of the subrecipients compliance requirements, they were not aware of the requirements to provide the Assistance Listings number and the auditors? requirements. Effect or Potential Effect: Alianza could inadvertently fail to ensure that subrecipients are aware of the award information and requirements imposed by regulations pertaining to the program. Questioned Costs: None noted. Context: Alianza did not state in the pass-through agreement the assistance listing number and the audit requirements which is required to be disclosed to the subrecipient. Identification as a Repeat Finding, if Applicable: Not applicable Recommendation: We recommend that Alianza ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the information listed at section 2 CFR 200.332 on Requirements for pass-through entities which includes the assistance listings numbers and title and 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.

Alianza Nacional de Campesinas, Inc. Management agrees with the finding. Although the organization provided this information to sub-recipients via different communications channels such as biweekly subgrantee meetings, email correspondence and other meetings, management was unaware that adding the assistance listing information to the written subrecipient agreements was required. Alianza will ensure to include this information in any future agreement with sub-recipients, when applicable, and will add this step to Alianza?s ?Standard Operating Procedures.?