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| Circular Oversight Requirements |
| The following are excerpts from the new A-133 Circular concerning oversight requirements for pass-through agencies. This is followed by Human Services' procedures in complying with the oversight requirements.
Pass-through entity responsibilities. "A pass-through entity shall perform the following for the Federal awards it makes:"
| 1. Identify federal awards made by informing each subrecipient of CFDA title and number, award name and number, award year, if the award is R&D, and name of federal agency. When some of this information is not available, the pass-through entity shall provide the best information available to describe the federal award. |
| DHS Procedures: |
- Each federally funded DHS contract identifies CFDA number and federal program name.
- DHS Audit Liaison (William Addison, CPA: AddisonB@michigan.gov) is available for questions concerning CFDA numbers and program names.
| 2. Advise subrecipients of requirements imposed on them by federal laws, regulations, and the provisions of contracts or grant agreements, as well as any supplemental requirements imposed by the pass-through entity. |
| DHS Procedures: |
- This Policy is still in Development
| 3. Monitor the activities of subrecipients, as necessary, to ensure that federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts or grant agreements and that performance goals are achieved. |
| DHS Procedures: |
- DHS implements a variety of on-sight program reviews, the nature of which depends on the program.
- Office of Internal Audit performs on-sight financial and/or compliance reviews of selected agencies.
| 4. Ensure that subrecipients pending $300,000 or more in federal awards during the subrecipient's fiscal year have met the audit requirements of this part for that fiscal year. |
| DHS Procedures: |
- All agencies that have federally funded contracts with DHS are monitored to determine if total federal funds exceed $300,000.
- All agencies whose federal funding with DHS exceeds $300,000 must submit to DHS a Circular A-133 audit report.
- All agencies whose federal funding with DHS is less than $300,000 must submit to DHS a letter stating a circular audit was unnecessary.
| 5. Issue a management decision on audit findings within six months after receipt of the subrecipient's audit report and ensure that the subrecipient takes appropriate and timely corrective action. |
| DHS Procedures: |
- DHS performs a limited desk review of all Circular A-133 audit reports.
- Circular audit reports with findings and questioned costs undergo a review process to determine DHS's position on audit issues.
- The subrecipient receives a management decision within six months of the date DHS received the complete audit report.
| 6. Consider whether subrecipient audits necessitate adjustment of the pass-through entity's own records. |
| DHS Procedure: |
- Management decision identifies DHS's position on audit issues.
| 7. Require each subrecipient to permit the pass-through entity and auditors to have access to the records and financial statements, as necessary, for the pass-through entity to comply with this part. |
| DHS Procedures: |
- DHS contracts require subrecipients to make available all books and records.
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