RANDOLPH COUNTY COMMISSIONLocal Government

Subrecipient Monitoring 2022-007 GENERAL INFORMATION: Grant Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Award Number: Assistance Listing #: 21.027 Federal Agency: Department of the Treasury CONDITION: We noted during our audit that the Randolph County Commission failed to properly monitor subrecipients. Specifically, there was no assurance that the allocated funds sent were expensed by the subrecipients. CRITERIA: 'Proper internal control over federal awards passed to subrecipients requires the establishment and maintenance of an effective system to provide reasonable assurance that the subrecipient is managing the federal award in compliance with federal statues, regulations, and terms and conditions of the federal award. 2 CFR Part 200.332 states, in part, that: "(a) 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 the definition of Federal award date in ? 200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x)Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi)Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii)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; (xiii) Identification of whether the award is R&D; and (xiv)Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ? 200.414. (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) (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. (4) (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with ? 200.405(d). (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. (b) Evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring described in paragraphs (d) and (e) of this section, which may include consideration of such factors as: (1) The subrecipient's prior experience with the same or similar subawards; (2) The results of previous audits including whether or not the subrecipient receives a Single Audit in accordance with Subpart F of this part, and the extent to which the same or similar subaward has been audited as a major program; (3) Whether the subrecipient has new personnel or new or substantially changed systems; and (4) The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also receives Federal awards directly from a Federal awarding agency).... (d) Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: (1) Reviewing financial and performance reports required by the pass-through entity. (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. (3) Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ?200.521. (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ?200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward.... (f) Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ?200.501. (g) Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records." QUESTIONED COSTS: $163,617 CONTEXT: Disbursements totaling $163,617 were made to subrecipients without activities being monitored to ensure expenditures of the subaward were being used for authorized purposes and in accordance with the grant guidelines. CAUSE: The Randolph County Commission did not have procedures in place to ensure subrecipient monitoring requirements were performed. EFFECT: Failure to properly monitor subrecipients increases the likelihood of errors or irregularities not being prevented or detected in a timely manner. Additionally, the risk of unallowable activities and unallowable costs is significantly increased. Management failed to comply with all applicable, material compliance requirements of the grant agreement. REPEAT FINDING: Yes PRIOR YEAR FINDING NUMBER: 2021-002 RECOMMENDATION: The Randolph County Commission is directed to review these regulations and comply with the provisions set forth therein. VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTIONS: We will comply and monitor subrecipient spending going forward.

2021 - 002 SUBRECIPIENT MONITORING Federal Program Information: Federal Agency and Program Name U.S. Department of the Treasury, Coronavirus Relief Fund CFDA # 21.019 Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.332a 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 the definition of Federal award date in ?200.1 of this part) of award to the recipient by the Federal agency; (v) Subaward Period of Performance Start and End Date; (vi) Subaward Budget Period Start and End Date; (vii) Amount of Federal Funds Obligated by this action by the pass-through entity to the subrecipient; (viii) Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; (ix) Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; (x) Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); (xi) Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; (xii) 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; (xiii) Identification of whether the award is R&D; and (xiv) Indirect cost rate for the Federal award (including if the de minimis rate is charged) per ?200.414. (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) (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: (A) The negotiated indirect cost rate between the pass-through entity and the subrecipient; which can be based on a prior negotiated rate between a different PTE and the same subrecipient. If basing the rate on a previously negotiated rate, the pass-through entity is not required to collect information justifying this rate, but may elect to do so; (B) The de minimis indirect cost rate. (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. Subrecipients can elect to use the cost allocation method to account for indirect costs in accordance with ?200.405(d). (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.? 2 CFR 200.332b indicates that all pass-through entities must ?evaluate each subrecipient's risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring.? 2 CFR 200.332d requires that pass-through entities ?monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subawards; and that subaward performance goals are achieved.? 2 CFR 200.332f state that pass-through entities must ?verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient?s Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in Section 2 CFR 200.501.? Condition: During our testing of the subrecipient monitoring compliance requirement, we identified one instance in our total sample of one subrecipient where the County did not clearly identify to subrecipients at the time of the subaward (or subsequent subaward modification) all of the required elements of 2 CFR 200.332. Though the County communicated many of the required items through various aspects of the program in place (e.g., application and related instructions and FAQs), it did not formalize that information in an official subaward document. Further, the County did not formally document the monitoring of the subrecipient or review of the subrecipient?s audit reports to ensure if an audit was required. Questioned Costs: N/A Context: Total federal expenditures for the Coronavirus Relief Fund were $2,852,628 for the year ended June 30, 2021. Total subrecipient expenditures for the year ended June 30, 2021 for the Coronavirus Relief Fund were $1,735,105. Cause: The Coronavirus Relief Fund program did not issue final guidance for the program until after payments were already distributed to subrecipients. The County did not have adequate policies and procedures in place to ensure that all required pass-through elements were included in the subaward at the time it was made or in subsequent subaward modifications if data elements changed or policies and procedures in place over the monitoring of subrecipients. Effect: Subrecipients may not be aware of all the required terms and conditions, such as audit requirements under 2 CFR 200 Subchapter F. Additionally, subrecipients may not be in compliance with all Federal statutes, regulations, and terms and conditions of the subaward since no formal monitoring was completed by the County. Recommendation: We recommend that the County update policies and procedures to ensure that all required elements are communicated to subrecipients at the time subawards are made or in subsequent subaward modifications if data elements change. Further, the County should ensure that risk assessments related to subrecipients and monitoring of subrecipients are formally documented. Management Response: We agree with the findings and will take the necessary corrective actions as noted in the corrective action plan noted.

2021 - 003 ALLOWABILITY Federal Program Information: Federal Agency and Program Name U.S. Department of the Treasury, Coronavirus Relief Fund CFDA # 21.019 Criteria: 2 CFR 200.303 requires that a non-federal entity must ?(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the comptroller General of the United States and the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.53 defines improper payments as ?any payment that should not have been made or that was made in an incorrect amount under statutory, contractual, administrative, or other legally applicable requirements.? 2 CFR 200.403 indicates that costs must ?be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity? and must ?be adequately documented?. Condition: For 9 of the 40 payroll transactions selected for testing, there was no documentation of either the time worked or leave taken to adequately support expenditures charged to the program. In addition, the County did not have proper internal controls in place to ensure all timesheets were reviewed prior to payment. Questioned Costs: $3,518 Context: Total federal expenditures for the Coronavirus Relief Fund were $2,852,628 for the year ended June 30, 2021. Total payroll expenditures charged to the Coronavirus Relief Fund for the year ended June 30, 2021 were $1,117,523. Cause: The County does not have adequate internal controls and policies and procedures in place to ensure that all payroll transactions are approved and adequately documented. Effect: The County is not in compliance with federal statutes, regulations, and terms and conditions of the federal award. Without sufficient internal controls in place, expenditures were paid that are not allowable. Recommendation: We recommend that the County enhance their policies and procedures to ensure they are in compliance with all federal statutes, regulations, and terms and conditions of the federal award. We recommend that the County also implement controls to ensure that expenditures are properly reviewed and approved before being charged to the federal award. Management Response: We agree with the findings and will take the necessary corrective actions as noted in the corrective action plan noted.