Arizona Association of Community Health Centers, Inc

Assistance Listing Numbers: 21.027 Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agency: U.S. Department of the Treasury Pass-Through Agencies: Maricopa County Pass-Through Grantor Identifying Number: None Award Year: November 1, 2021 through September 30, 2026 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR 200.332 (e) & (g) - pass-through entities must monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Condition: While AACHC performed several of the required subrecipient monitoring tasks, AACHC's system of internal controls did not include a process to monitor the subrecipients' financial and performance reports by verifying that subrecipients are audited if they meet the single audit criteria and ensure that subrecipients take corrective action on single audit findings. Questioned Costs: N/A Context: In a population of five subrecipients, we noted that for all five subrecipients, while AACHC performed several of the required subrecipient monitoring tasks, AACHC did not monitor subrecipient activity through reviewing financial and performance reports, verify that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. This is deemed to be a material weakness in internal control over compliance. Effect: The system of internal controls was not properly designed to include a process to review financial and performance reports, verifying that subrecipients are audited if the meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Cause: AACHC was not aware of the requirements within the Uniform Guidance for pass-through entities to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Identification of Repeat Finding: Not a repeat finding. Recommendation: AACHC should update their subrecipient monitoring policies and procedures to specifically include a process to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. We also recommend AACHC regularly attend trainings on the Uniform Guidance to ensure they are knowledgeable of the required compliance procedures. Views of Responsible Officials and Planned Corrective Actions: Management of AACHC concurs with the finding. See Corrective Action Plan.

Assistance Listing Numbers: 93.332 Program: Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges Federal Agency: Department of Health and Human Services Pass-Through Agencies: N/A Pass-Through Grantor Identifying Number: NN/A Award Year: August 27, 2021 through August 26, 2024; August 27, 2024 through August 26, 2027 Compliance Requirement: Subrecipient Monitoring Criteria: In accordance with 2 CFR 200.332 (e) & (g) - pass-through entities must monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Condition: While AACHC performed several of the required subrecipient monitoring tasks, AACHC's system of internal controls did not include a process to monitor the subrecipients' financial and performance reports by verifying that subrecipients are audited if they meet the single audit criteria and ensure that subrecipients take corrective action on single audit findings. Questioned Costs: N/A Context: In a population of twelve subrecipients, we noted that for all twelve subrecipients, while AACHC performed several of the required subrecipient monitoring tasks, AACHC did not monitor subrecipient activity through reviewing financial and performance reports, verify that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. This is deemed to be a material weakness in internal control over compliance. Effect: The system of internal controls was not properly designed to include a process to review financial and performance reports, verifying that subrecipients are audited if the meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Cause: AACHC was not aware of the requirements within the Uniform Guidance for pass-through entities to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. Identification of Repeat Finding: Not a repeat finding. Recommendation: AACHC should update their subrecipient monitoring policies and procedures to specifically include a process to monitor subrecipient activity through reviewing financial and performance reports, verifying that subrecipients are audited if they meet the single audit criteria, and ensure that subrecipients take corrective action on single audit findings. We also recommend AACHC regularly attend trainings on the Uniform Guidance to ensure they are knowledgeable of the required compliance procedures. Views of Responsible Officials and Planned Corrective Actions: Management of AACHC concurs with the finding. See Corrective Action Plan.