Interior Community Health CenterNon-Profit

COVID-19 Healthy and Equitable Communities-Enhancing Local Capacity-Alaska Initiative to Address COVID-19 Among High Risk, Rural, and Underserved Alaskans---Assistance Listing No. 93.391; Grant No. 601-314-22001; Grant period: Year ended June 30, 2023; Pass-through entity name: State of Alaska- Department of Health and Social Services-Division of Public Health Healthy and Equitable Communities-Enhancing Local Capacity-Immunization Cooperative Agreements--- Assistance Listing No. 93.268; Grant No. 601-314-22001; Grant period: Year ended June 30, 2023; Pass-through entity name: State of Alaska- Department of Health and Social Services-Division of Public Health Criteria and Condition: In accordance with the 2 CFR Part 200, Appendix XI OMB Compliance Supplement May 2023 section “Subrecipient Monitoring” and in accordance with 2 CFR section 200.331(a) says a pass-through entity (PTE) must (1) identify the award and applicable requirements clearly to their subrecipients. This includes clearly identifying the award as a subaward at the time of subaward by providing information described in 2 CFR section 200.331(a)(1). In accordance with the OMB Compliance Supplement May 2023 section “Other Audit Advisories” when COVID-19 funding is subawarded by a pass-through entity from an existing program, the information furnished to subrecipients should distinguish the subawards of incremental COVID-19 funding included in the subawards from non-COVID-19 funding. Without this clear identification, there is a high risk the nine subrecipients were not properly informed they received specific non-COVID-19 and COVID-19 federal funds. Cause: The Center served at the request of the Fairbanks North Star Borough as their designated agency to distribute the Health and Equitable funding from the State of Alaska. The Center did not receive the proper information, training, or guidance from the pass-through entity State of Alaska on how to be a compliant pass-through entity. In effect, the Center did not know to review the requirements from OMB Compliance Supplement May 2023 or 2 CFR section 200.331(a)(1) during the process and procedures of disbursing out awards to subrecipients. The Center used a template used by the State of Alaska. Potential Effect: We estimate taht three of the nine subrecipients potentially did not properly report the Assistance Listing Numbers and grant awards on their FY23 SEFA. This would quantify to approximately 40 percent of the pass-through funds. Questioned Costs: none noted Context: Auditor selected a random sample of six out of nine subrecipients which is approximately 66 percent of the total population. We believe this sample is representative of the population. We inspected the associated subrecipient agreements and inquired with management to validate if they were in compliance with properly identifying to the subrecipients in accordance with the OMB Compliance Supplement May 2023 and 2 CFR 200.331(a)(1). Recommendations: We recommend the Center ensure the required factors of 2 CFR 200.331(a) (1) and the OMB Compliance Supplement May 2023 are identified clearly to the subrecipients in their agreements. We recommend all Subrecipient Monitoring requirements out of the OMB Compliance Supplement are read and understood and implemented for any future subrecipient activity. We recommend reaching out to any subrecipients who have already received these funds to ensure they have properly stated SEFAs. View of Responsible Officials: Management agrees with the finding. Please see the Corrective Action Plan.