Illuminate Colorado, Inc

Finding 2024-001: Subrecipient Monitoring Federal Program: Assistance Listing #21.027 - Coronavirus State and Local Recovery Funds. Criteria: A pass-through entity must ensure that every subaward is clearly identified to a subrecipient as a subaward and includes the information provided below. A pass-through entity must provide the best available information when some of the information below is unavailable. A pass-through entity must provide the unavailable information when it is obtained. (2 CFR 200.332(b)). Condition: Illuminate Colorado has issued subawards to subrecipients to carry out part of its Coronavirus State and Local Recovery Funds program. 2 out of 4 subrecipients were selected for testing. The subawards for these subrecipients were missing the following Federal award identification information:  Subrecipient's unique entity identifier.  Federal Award Identification Number (FAIN).  Federal Award Date.  Amount of Federal Funds Obligated in the subaward.  Total Amount of the Federal Award committed to the subrecipient by the pass-through entity.  Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA).  Name of the Federal agency and contact information for the awarding official of the passthrough entity. Item required in accordance with 2 CFR 200.332(b) (formerly 200.331(a)) of the Uniform Guidance.  Identification of whether the Federal award is for research and development. Questioned Costs: None. Cause and Effect: Illuminate Colorado has adding provisions in its financial policies and procedures to include the required information in its subawards to subrecipients of Federal funds. While some of the information required by 2 CFR 200.332(b) has been included in the subaward, the information noted above was not. As a result, Illuminate Colorado issued incomplete Federal award information to its subrecipients for this program. This may cause subrecipients to be unable to adhere to any specific compliance requirements, federal laws, regulations, and terms and conditions of the award resulting in noncompliance with all federal rules applicable to the program for which Illuminate Colorado is ultimately responsible. Recommendation: Properly identify subrecipients and ensure subawards include Federal award identification information. Illuminate Colorado can ensure all the required Federal award identification information through a subaward checklist and review by appropriate organization management. Management’s Response: Illuminate Colorado has developed a new process for properly identifying subrecipients and ensuring all required federal award identification information is included in each subaward prior to issuance. This process includes the use of an updated subaward checklist and management review prior to execution of subaward agreements.

Federal Program: Assistance Listing #93.590 - Community-based Child Abuse Prevention Grant Program Assistance Listing #93.912 - Rural Communities Opioid Response Program Criteria: Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). Condition: Illuminate Colorado has established a policy to time Federal drawdown requests to ensure that Federal cash on hand is sufficient to be disbursed to third party vendors within 10 days of receipt. 2 out of 49 program disbursements to external vendors were made 79 to 90 days after receipt of funds for Community-based Child Abuse Prevention Grant program. 32 out of 46 program disbursements to external vendors were made 14 to 186 days after receipt of funds for Rural Communities Opioid Response program. Questioned Costs: None. Cause and Effect: Illuminate Colorado experienced cashflow issues during 2023 resulting in usage of program receipts for other programs. In addition, vendors utilized for direct Federal assistance programs were not identified and prioritized for federal drawdown receipts. As a result, Illuminate Colorado did not minimize the time elapsing between the drawdown and transfer of funds from the US Treasury and disbursement by the non-federal entity for direct program or project costs. Recommendation: Since Illuminate Colorado is a direct recipient of federal program funds, we recommend Illuminate Colorado identify and pay external vendors participating in this program within 10 days of receipt of program funds in accordance with its financial policies and procedures. In addition, non-program cash flow should be increased to allow enough working capital to disburse program funds to external vendors utilized for this program. Management’s Response: Illuminate Colorado has improved invoicing procedures to ensure timely submission of invoices across the board to minimize time elapsed between submission of invoices to funders and reimbursement of those invoices. In addition, Illuminate Colorado has been seeking increased working capital via a larger line of credit or other sources to address cash flow issues. Finally, Illuminate Colorado is in process of developing a Standard Operating Procedure to ensure consistent identification of vendors utilized for direct Federal assistance programs in order to prioritize payment of those vendors with federal drawdown receipts.

Federal Program: Assistance Listing #93.912 - Rural Communities Opioid Response Program Criteria: In accordance with the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are 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: Illuminate Colorado was a direct recipient of Rural Communities Opioid Response Program funds. Illuminate Colorado made first-tier subawards of more than $30,000 to two subrecipients to carry out part of the Rural Communities Opioid Response Program These firsttier subawards were not reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None. Cause and Effect: Primary Project Director and Primary Program Manager assigned to this grant were both out on parental leave during Q4 of 2023 when this Federal Grant was being initiated internally. Back up personnel assigned to provide coverage during the leave and review the terms and conditions of the award did not identify the Federal Funding Accountability and Transparency Act Persons reporting requirements. Recommendation: We recommend Illuminate Colorado communicate Federal Funding Accountability and Transparency Act reporting requirements to program management. This can be communicated by flowcharting/decision tree. Management’s Response: Illuminate Colorado has developed a new process for initiating federal grants that includes a review of Terms and Conditions by multiple individuals to ensure all required Terms and Conditions are identified and implemented. This process includes documentation of compliance with requirements for subrecipients.