The German Marshall Fund of the US - A Memorial to the Marshall Fund

Significant Deficiency/Other Compliance Matters Finding 2021-003: Subrecipient Monitoring Federal agency: U.S. Agency for International Development Program: USAID Foreign Assistance for Programs Overseas Assistance Listing number: 98.001 Criteria: Prime recipients of U.S. government (USG) funds are responsible for managing and monitoring each project, program, sub award, function or activity supported by the award (2 CFR 200.329, monitoring and reporting program performance). 2 CFR 200.332 requires that prime recipients evaluate subrecipients? risk of noncompliance with federal statutes, regulations and terms and the conditions of the sub award and to provide monitoring based on this evaluation. 2 CFR 200.332 requires organizations that provide sub grants and USG funds to other entities to provide assurance that each subrecipient administers the federally funded subawards in compliance with federal requirements. 2 CFR 200.332 states that the monitoring of the subrecipients must include verifying that every subrecipient is audited as required by Subpart F. Condition: GMF established policies and procedures over subrecipient monitoring, including agreement execution and risk assessment. However, we believe the overall approach has been generic and not tailored to specific risks for each recipient. As of March 1, 2020, GMF established a new risk assessment scorecard with detailed consideration on the risk of each recipient. However, GMF does not have documentation of the approved monitoring plan based on the risk of the recipient. In addition, other elements of the criteria are lacking based on testwork. Cause: There appears to be a lack of maintaining documentation related to the subrecipient monitoring compliance requirement. Effect: GMF?s subrecipients are not being monitored to their respective level of risk as called for by 2 CFR 200. Questioned costs: None Repeat finding: Yes, 2020-001 Recommendation: We recommend that GMF establish a risk assessment policy with a designated individual(s) responsible for effective implementation as well as an enhanced documentation over the risk assessment and monitoring plan, and maintain documentation of the awarding agency?s approval of grantees. Views of responsible officials: GMF agrees with the finding. See corrective action plan.

Finding 2021-004: Reporting - Federal Funding Accountability and Transparency Act (FFATA) Federal agency: U.S. Agency for International Development Program: USAID Foreign Assistance for Programs Overseas Assistance Listing number: 98.001 Criteria: Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 and codified in 2 CFR Part 170, recipients (i.e., 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). Condition: GMF does not have policies and procedures in place to comply with FFATA requirements. Cause: There appears to be a lack of procedures and knowledge around the compliance of FFATA requirements. Effect: GMF did not comply with FFATA requirements and the government cannot track subawards timely. Questioned Costs: None Repeat Finding: No Recommendation: We recommend that GMF establish policies and procedures with a designated individual(s) responsible for effective implementation over the compliance requirements of FFATA. Views of responsible officials: GMF agrees with the finding. See corrective action plan.

Significant Deficiency/Other compliance matters Finding 2020-001: Subrecipient Monitoring Federal agency: U.S. Agency for International Development Program: USAID Foreign Assistance for Programs Overseas CFDA number: 98.001 Criteria: Prime recipients of U.S. government (USG) funds are responsible for managing and monitoring each project, program, sub award, function or activity supported by the award (2 CFR 200.328, monitoring and reporting program performance). 2 CFR 200.331 requires that prime recipients evaluate subrecipients? risk of noncompliance with federal statutes, regulations and terms and the conditions of the sub award and to provide monitoring based on this evaluation. 2 CFR 200.500-521 requires organizations that provide sub grants and USG funds to other entities to provide assurance that each subrecipient administers the federally funded subawards in compliance with federal requirements. 2 CFR 200.331 states that the monitoring of the subrecipients must include verifying that every subrecipient is audited as required by Subpart F. Condition: GMF established policies and procedures over subrecipient monitoring, including agreement execution and risk assessment. However, we believe the overall approach has been generic and not tailored to specific risks for each recipient. As of March 1, 2020, GMF established a new risk assessment scorecard with detailed consideration on the risk of each recipient. However, GMF does not have an approved monitoring plan based on the risk of the recipient. In addition, other elements of the criteria are lacking based on testwork. Cause: There appears to be a lack of tailoring and monitoring oversight on this process. Effect: GMF?s subrecipients are not being monitored to their respective level of risk as called for by 2 CFR 200. Questioned costs: None Repeat finding: Yes Recommendation: We recommend that GMF establish a risk assessment policy with a designated individual(s) responsible for effective implementation as well as an enhanced approval process over subrecipient agreements, monitoring plan, and maintain documentation of the awarding agency?s approval of grantees. Views of responsible officials: See corrective action plan.

Finding 2019-003: Subrecipient Monitoring Federal agency: U.S. Agency for International Development Program: USAID Foreign Assistance for Programs Overseas CFDA number: 98.001 Criteria: Prime recipients of U.S. government (USG) funds are responsible for managing and monitoring each project, program, sub award, function or activity supported by the award (2 CFR 200.328, monitoring and reporting program performance). 2 CFR 200.331 requires that prime recipients evaluate subrecipients? risk of noncompliance with federal statutes, regulations and terms and the conditions of the sub award and to provide monitoring based on this evaluation. 2 CFR 200.500-521 requires organizations that provide sub grants and USG funds to other entities to provide assurance that each subrecipient administers the federally funded subawards in compliance with federal requirements. 2 CFR 200.331 states that the monitoring of the subrecipients must include verifying that every subrecipient is audited as required by Subpart F. Condition: GMF established policies and procedures over subrecipient monitoring, including agreement execution and risk assessment. However, we believe the overall approach has been generic and not tailored to specific risks for each recipient. In addition, other elements of the criteria are lacking based on testwork. Cause: There appears to be a lack of tailoring and monitoring oversight on this process. Effect: GMF?s subrecipients are not being monitored to their respective level of risk as called for by 2 CFR 200. Questioned costs: None Repeat finding: No Recommendation: We recommend that GMF established a risk assessment policy with a designated individual(s) responsible for effective implementation as well as an enhanced approval process over subrecipient agreements and maintain documentation of the awarding agency?s approval of grantees. Views of responsible officials: See corrective action plan.

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