Puerto Rico Public Private Partnerships AuthorityLocal Government

Criteria: As per §200.430 Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, (1), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: 1. (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; 2. (ii) Be incorporated into the official records of the non-Federal entity; 3. (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; 4. (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policy. CH7 Payments and Cash Management, Appendix 7-A: Policy and Procedures Specific Terms and Acronyms establishes that “an allocation of time spent on supporting federal award work would be available to confirm calculation of a portion of salary allocable to federal award. Certified Labor Summary should be signed (electronically or manually) by an authorized representative. Such time records should coincide with one or multiple pay periods.” Condition: On examined documents for payment of payroll, from a sample of fifteen (15) employees, twelve (12) of them did not comply with the requirement to prepare the Weekly State Management Cost Report (SMC). Cause: The Program did not implement effective internal control procedures to keep a segregated tracking of actual time used in each federal program. Effects: Not having a proper internal control in place to keep a segregated tracking of actual time used in each federal program may lead to noncompliance with the allowable costs/cost principles and time and effort requirements. Questioned Costs: $42,102.08 Identification as a repeat finding: Finding is a repeat of a finding in the immediately prior year and was identified as finding number 2019-04. Recommendation: We recommend management to implement a procedure to keep a segregated tracking of actual time used in each federal program and for obtain and validate all required supporting documentation for salaries charged to the federal award.

Criteria: §2 CFR 200.439 Equipment and other capital expenditures establish that “(1) Capital expenditures for general purpose equipment, buildings, and land are unallowable as direct charges, except with the prior written approval of the Federal awarding agency or pass-through entity, (2) Capital expenditures for special purpose equipment are allowable as direct costs, provided that items with a unit cost of $5,000 or more have the prior written approval of the Federal awarding agency or pass-through entity.” Condition: From a sample of fifteen (15) equipment, COR3 was unable to provide supporting evidence for approval from the federal agency for one (1) purchase transaction that requires such prior approval. Cause: Lack of supervision to ascertain compliance with requirements and procedures established for purchase of specialized equipment with a cost of $5,000 or more. Effects: Lack of supervision may result in noncompliance with the allowable costs/cost principles requirements. Questioned Costs: $54,959.25 Recommendation: We recommend management to increase the level of supervision to ascertain the established requirements for the purchase of specialized equipment are met.

Criteria: • • §2 CFR 200.430 (i) Standards for Documentation of Personnel Expenses, establishes that “(1) Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;” • • The Human Resources manuals that establish the hire procedures for the employee’s Authority, in its article 6.2 Job Description, establishes that the Authority shall prepare and keep up to date, for each authorized position in the career service, a clear and precise description of the essential and marginal duties and responsibilities, degree of authority, responsibility and supervision assigned to it. Condition: Four (4) employees, out of a sample of fifteen (15) files examined, had no job descriptions. Cause: The Program did not follow up the established procedures for hiring of personnel. Effects: Condition may result in noncompliance with the requirements of record retention and with internal controls as in place for COR3. Questioned Costs: None Recommendation: We recommended management to monitor the implementation of procedures in place to maintain updated employee’s personal file.

Criteria: • In Title 31, Subtitle V, §6304. Using grant agreements, establishes that “An executive agency shall use a grant agreement as the legal instrument reflecting a relationship between the United States Government and a State, a local government, or other recipient when— (1) the principal purpose of the relationship is to transfer a thing of value to the State or local government or other recipient to carry out a public purpose of support or stimulation authorized by a law of the United States instead of acquiring (by purchase, lease, or barter) property or services for the direct benefit or use of the United States Government; and (2) substantial involvement is not expected between the executive agency and the State, local government, or other recipient when carrying out the activity contemplated in the agreement.” • CH2, Sec. 7, Application and Award Management Manual, establish in the Application and Award Management Policy that “Cor3 will (7) require subrecipients to sign the subrecipient agreements at Request for Public Assistance (RPA) and a subrecipient modification at issuance of Project Worksheet (PW)”. Condition: COR3 was unable to provide the agreements for ten (10) subrecipients from a sample of sixty (60). The subrecipients were the following: The condition could result in noncompliance with procurement requirements applicable to COR3. Questioned Costs: Could not be determined. Recommendation: We recommended management to make sure that agreements are executed before disbursements are expected to be made.

Criteria: • 2 CFR 200.313 (d) (1) establishes that property records must be maintained and should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. 2 CFR 200.313 (d) (3) establishes that a control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. Condition: While examined the property report for the year ended as of June 30, 2020, from a sample of 30 units, the following observations were identified: • • One (1) unit was replaced, and the replacement was no recorded in the property report. • • Description for one (1) unit does not match with information included in the property report. • • The serial numbers for six (6) units do not match with serial numbers per property report. • • Two (2) units do not have assets ID and/or tag number in the property report. • • The tag number for two (2) units do not match with tag number per property report. • • Two (2) units were damaged, and not in in use, however, property report was not updated to reflect it. • • Two (2) units appear assigned to incorrect custody. • • The property report does not include the percentage of federal participation on cost of units. Cause: Lack of supervision to keep the property report updated. Effects: Conditions may result in noncompliance with the requirements for equipment and real property management and with internal controls of COR3. Questioned Costs: None. Recommendation: We recommended management to increase supervision to maintain an updated property report.

Criteria: 2 CFR §200.512 (a) (1) establishes that the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Condition: COR3 did not submit the required data collection form and reporting package for the year ended June 30, 2019 and 2020, within the required period. Cause: Lack of procedures requiring a review of deadlines established for the submission of required annual reporting. In addition, the lack of an integrated financial accounting system that considers all funds administered, including state and federal awards. The accounting is maintained for funds received and disbursed, which are recorded in "Excel" program spreadsheets for both state and federal awards. In addition, the Program maintains separate accounting records, for transactions related to the Grants using the same "Excel" program spreadsheets system. This creates delays in the performance of the single audit procedures and the timely delivery of the single audit reporting package. Effects: Condition may result in noncompliance with the requirements for Reporting. Questioned Costs: None. Identification as a repeat finding: Finding is a repeat of a finding in the immediately prior year and was identified as first bullet in finding number 2019- 05. Recommendation: We recommend management to establish calendars to review submission of required reporting in order to ascertain that all team members be aware of due dates.

Criteria: FEMA State Agreement, Section V. Reporting, (B) establishes that “the State shall submit performance progress reports in compliance with each program identified in the Agreement to the FEMA Regional Office 30 days after the end of the first quarter following the federal award date. Reports are due on January 30, April 30, July 30 and October 30. Federal Acquisition Regulation clause 52.204-10 stablishes that prime contractor awarded a federal contract or order are required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor awards any sub-contract greater than $30,000. 2CFR Chapter 1, Part 170 Reporting sub-award and executive compensation, prime awardees awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: • • COR3 did not submit the required quarterly performance report for the quarter ended in September 2019 within the required period. • • COR3 did not submit the required Federal Funding Accountability Transparency Act (FFATA) reports of July, August and November 2019 for the following contracts: Cause: Lack of procedures regarding a review of deadlines established for the submission of required reporting. Effects: Condition may result in noncompliance with the requirements for Reporting. Questioned Costs: None. Identification as a repeat finding: Second bullet is a repeat of a finding in the immediately prior year and was identified as third bullet in finding number 2019-05. Recommendation: We recommend management to establish calendars to review submission of required reporting in order to ascertain that all team members be aware of due dates.

Criteria: • §200.303 Internal controls establishes that “The 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, (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards, (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards., (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings. • • 2 CFR §200.332 Requirements for pass-through entities establishes that “All pass-through entities must: 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; and (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings”. Condition: The Chapter 11 Subrecipients Management and Monitoring Manual, subrecipients with risk assessment profile classified as High-High Risk (HH), require an annual site visit. However, during the year ended June 30, 2020, from six (6) subrecipients classified as HH, two (2) were not visited during the period. The subrecipients not visited were the following: Cause: Lack of implementation of work plan that includes monitoring process for at least major subrecipients before year end, in order to avoid noncompliance on subrecipients’ procedures. Effects: • • Noncompliance may be performed by subrecipients without timely evaluation to remediate possible questioned costs, which may result in delay receipt of funds through remediation be implemented. • • Incomplete monitoring process can prevent COR3 from timely detection of a material noncompliance from subrecipients. Questioned Costs: None. Identification as a repeat finding: Finding is a repeat of a finding in the immediately prior year and was identified as finding number 2019-07. Recommendation: • • We recommend management to implement a work plan for monitoring subrecipients to ascertain that major subrecipients be monitored during the year, or at reaching to determine threshold on used federal funds used in order to timely react to and avoid possible non-compliances. • • In addition, we recommended management to ascertain that all procedures related to the monitoring process be implemented.

1. Criteria: In title 31, Subtitle V, §6304. Using grant agreements, establishes that “An executive agency shall use a grant agreement as the legal instrument reflecting a relationship between the United States Government and a State, a local government, or other recipient when— (1) the principal purpose of the relationship is to transfer a thing of value to the State or local government or other recipient to carry out a public purpose of support or stimulation authorized by a law of the United States instead of acquiring (by purchase, lease, or barter) property or services for the direct benefit or use of the United States Government; and (2) substantial involvement is not expected between the executive agency and the State, local government, or other recipient when carrying out the activity contemplated in the agreement.” Condition: From a sample of sixty (60) subrecipient agreements, forty-seven (47) had payments before the date the subrecipient agreement were signed, as follows: Cause: The Authority did not execute the subrecipient agreements before to disbursing the federal funds. Effects: Disburement of federal funds without formal subrecipient agreements would lead to noncompliance event. Questioned Costs: None. Recommendation: We recommend management to implement a plan to ascertain compliance with required procedures to perform agreements with subrecipients before disbursements commence.

Finding Number: 2019-02 Federal Program: CFDA No. 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Category: Internal Control/Compliance Compliance Requirement: Activities Allowed or Unallowed/Allowable Costs/Cost Principles Criteria: ?200.302 (a) Financial management, establishes that, ?Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award?. ?200.334 Retention requirements for records establish that ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient?. Per Agreement between the Government of Puerto Rico (GPR) and the Federal Emergency Management Agency (FEMA); for each request for reimbursement, the Program will perform 100% validate of the completeness (the funding request is supported by detailed documentations supporting the dollar amount request) and compliance (adherence to all relevant statutory regulatory and programmatic requirements), specifically as follows: for subrecipients designed as High Risk the GPR will performed 100% validation (completeness and compliance) of funding request prior to drawdown by the recipients or disbursement to the Sub-recipients. Condition: On April 18, 2019, the Program made a disbursement to a subrecipient without having validated the 100% of the compliance report. Subsequently, the Program performed the compliance report and requested the support evidence to the subrecipient. On November of 2019, the subrecipient, returned the funds received for several project worksheet (PW), which included the referred disbursement. As informed in the return letter by the subrecipient, funds were returned since they did not have all the required support for this transaction. The transaction is the following: Cause: The Program did not follow the internal developed policies and procedures applicable to the review and reimbursement of FEMA recovery funds, a responsibility that the Program assumed on April 1, 2019, when the Program entered into an agreement to assume the responsibility to review and reimbursement approval of FEMA recovery funds. Such policies and procedures require that all disbursement issued to subrecipients that are categorized as High-High risk be accomplished with a 100% of completeness and compliance procedures. This disbursement was performed during the period in which the Program had the responsibility to review and approve the disbursements. Effects: Condition may result in noncompliance with the activities allowed or unallowed/allowable costs/cost principles requirements. Questioned Costs: $412,485.26 Recommendation: We recommend the Authority to ascertain it obtain all required supporting documents before the disbursement the funds to subrecipients occurs.

Finding Number: 2019-03 Federal Programs: CFDA No. 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Category: Internal Control/Compliance Compliance Requirement: Record retention Criteria: ?200.334 Retention requirements for records establish that ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award, must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient?.?200.337 Access to records establish that ?(a) Records of non-Federal entities. The Federal awarding agency, Inspectors General, the Comptroller General of the United States, and the pass-through entity, or any of their authorized representatives, must have the right of access to any documents, papers, or other records of the non- Federal entity which are pertinent to the Federal award, in order to make audits, examinations, excerpts, and transcripts. The right also includes timely and reasonable access to the non-Federal entity's personnel for the purpose of interview and discussion related to such documents?. Per Chapter 8 Record Retention and Access, ?Many of the record retention requirements will be handled by Program grant management system, Puerto Rico Disaster Recovery Solution (PR DRS). Records will be retained in an electronic form in PR DRS and transferred to the Federal awarding agency as requested. The records will be available for review or audit by authorized parties and accessible to public except where prohibited by law?. Condition: The Program could not made accessible the supporting documents for seven (7) transactions, out of a sample of sixty (60) items. These transactions were the following:Cause: During several months of the first year, evaluation of supporting documents for requested funds of subrecipients were directly managed and handled by FEMA on the EMMIE system, therefore, the Authority should have transferred the documents to PR DRS to provide assurance of compliance with record retention requirements. Also, the Program operated using the technological resources of other governmental agency, Puerto Rico Management and Emergency Agency (PREMA); however, at the transfer of Program?s operations to the AAAP, it was unable to access certain information of transactions recorded using PREMA?s technological resources. Effects: Condition may result in noncompliance with the requirements of record retention. Questioned Costs: None Recommendation: We recommend the Authority to contact FEMA or the subrecipients in order to obtain the required support for the transactions.

Finding Number: 2019-04 Federal Programs: CFDA No. 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Category: Compliance Compliance Requirement: Allowable Costs/Cost Principles Time and Effort Criteria: CH7 Payments and Cash Management, Appendix 7-A: Policy and Procedures Specific Terms and Acronyms establishes that ?an allocation of time spent on supporting federal award work would be available to confirm calculation of a portion of salary allocable to federal award. Certified Labor Summary should be signed (electronically or manually) by an authorized representative. Such time records should coincide with one or multiple pay periods?. As per ?200.430 Compensation - personal services, (i) Standards for Documentation of Personnel Expenses, (1), Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: (i) Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; (ii) Be incorporated into the official records of the non-Federal entity; (iii) Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities (for IHE, this per the IHE's definition of IBS); (iv) Encompass federally-assisted and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non-Federal entity's written policyCondition: ? The Program did not implement effective procedures to keep a segregated tracking of actual time used in each federal program. ? On examined documents for payment of payroll, from a sample of ten (10) employees, five (5) of them did not comply with requirement to prepare the Weekly State Management Cost Report. Cause: Lack of supervision to ascertain compliance with all requirements to record administrative costs. Effects: Condition may result in noncompliance with the allowable costs/cost principles and time and effort requirements. Questioned Costs: $439,658 Recommendation: We recommend management to implement a procedure for the obtention and validation of all required supporting documentation for salaries charged to the federal award.

Finding Number: 2019-05 Federal Programs: CFDA No. 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Category: Compliance Requirement Reporting Criteria: ? 2 CFR ?200.512 (a) (1) establishes that the audit must be completed and the data collection form described in paragraph (b) of this section and reporting package described in paragraph (c) of this section must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. ? FEMA State Agreement, Section V. Reporting, A(1) establishes that ?The State shall submit complete and accurate Federal Financial Reports (Standard Form 425) to the FEMA Regional Office 30 days after the end of the first federal quarter following the federal award date for each program?. ? Federal Acquisition Regulation clause 52.204-10 stablishes that prime contractor awarded a federal contract or order are required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor awards any sub-contract greater than $30,000. ? 2CFR Chapter 1, Part 170 Reporting sub-award and executive compensation, prime awardees awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: ? The Program did not submit the required data collection form and reporting package within the required period. ? The Program did not submit the required financial report (SF425) of June and September 2018 within the required period. ? The Program did not submit the required Federal Funding Accountability Transparency Act (FFATA) reports of July and August 2018 within the required period. Cause: Lack of procedures requiring the review of deadlines established for the submission of required annual reporting.Effects: The reports were not submitted on time in order to comply with requirements. Questioned Costs: None. Recommendation: We recommend to the Authority to establish calendars to review submission of required reporting in order to ascertain that all team members be aware of due dates.

Finding Number: 2019-06 Federal Programs: CFDA No. 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Category: Internal Control/ComplianceCompliance Requirement: Reporting Criteria: ? FEMA State Agreement, Section V. Reporting, (B) establishes that ?the State shall submit performance progress reports in compliance with each program identified in the Agreement to the FEMA Regional Office 30 days after the end of the first quarter following the federal award date. Reports are due on January 30, April 30, July 30 and October 30. ? Federal Acquisition Regulation clause 52.204-10 stablishes that prime contractor awarded a federal contract or order are required to file a FFATA sub-award report by the end of the month following the month in which the prime contractor awards any sub-contract greater than $30,000. ? 2CFR Chapter 1, Part 170 Reporting sub-award and executive compensation, prime awardees awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Condition: ? COR3, a division of the Authority, was unable to provide evidence of submission of performance reports. ? COR3, a division of the Authority, was unable to provide evidence of submission of monthly FFATA reports for all months of the year. Cause: Lack of procedures referring a review as deadlines established for the submission of required annual reporting. In addition, the lack of an integrated financial accounting system that considers all funds administered, including state and federal awards. The accounting is maintained for funds received and disbursed, which are recorded in "Excel" program spreadsheets for both state and federal awards. In addition, the Program maintains separate accounting records, for transactions related to the Grants using the same "Excel" program spreadsheets system. This creates delays in the performance of the single audit procedures and the timely delivery of the single audit reporting package. Effects: The reports were not submitted on time in order to comply with requirements of reporting. Questioned Costs: None Recommendation: We recommend to the Program to establish calendars to review submission of required reporting in order to ascertain that all team members be aware of due dates.

Finding Number: 2019-07 Federal Programs: CFDA No. 97.036 Disaster Grants - Public Assistance (Presidentially Declared Disasters) Category: Internal Control/Compliance Compliance Requirement: Subrecipients Monitoring Criteria: ?200.303 Internal controls establishes that ?The 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, (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards, (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards., (d) Take prompt action when instances of noncompliance are identified including noncompliance identified in audit findings?. 2 CFR ?200.332 Requirements for pass-through entities establishes that ?All pass-through entities must: 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; and (4) The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings?. Condition: The Chapter 11 Subrecipients Management and Monitoring Manual, subrecipients with risk assessment profile classified as High-High Risk (HH), require an annual site visit. However, during the year ended June 30, 2019, from twelve (12) subrecipients classified as HH, only two were visited during the period and other four were visited during the subsequent period. The following subrecipients were not visited:Cause: Missing work plan including monitoring process for at least major subrecipients before year conclude in order to avoid noncompliance on subrecipients procedures. Effects: Noncompliance may be performed by subrecipients without timely evaluation to remediate possible questioned costs, which may result in delay receipt of funds through remediation be implemented. Questioned Costs: None. Recommendation: We recommend to management to implement a work plan for monitoring subrecipients to ascertain that major subrecipients be monitored during the year, or at reaching to determine threshold on used federal funds used in order to timely react to and avoid possible non-compliances.