| Preventive Health and Health Services Block Grant
funded solely with Prevention and Public Health
Funds |
Subrecipient Monitoring. Public Health and EMSA did not
evaluate each subrecipient's risk of noncompliance with federal
statutes, regulations, and the terms and condition of the subaward. |
2015-16 |
| Remains Uncorrected. In approximately May 2017, the Branch
reviewed all federal statutes, regulations, and the terms and
conditions of the federal award to determine whether policies and
procedures existed and were operating effectively to ensure
compliance with all requirements.
The Branch also determined policies and procedures needed to be
developed and worked to create them.
In August 2017, the Branch developed a risk assessment tool and
distributed it to Public Health programs and EMSA.
In October 2017, Public Health revised the risk assessment tool.
In November 2017, the Branch distributed the risk assessment
tool.
During September – November 2018, the Branch will:
Re-review all federal statutes, regulations, and the terms
and conditions of the federal Public Health and Health
Services Block Grant (PHHSBG) Award to determine if the
existing policies, procedures, and the risk assessment tool
are designed appropriately.
Develop a new or revise the existing subrecipient risk
assessment policies, procedures, and the risk assessment
tool.
Distribute the revised subrecipient risk assessment tool to
Public Health programs and EMSA, if necessary.
Follow up with Public Health programs and EMSA to
ensure they complete the finalized risk assessment tool for
each subrecipient.
Maintain files for completed risk assessments.
EMSA did not utilize its PHHSBG to fund any subrecipients
agreements. EMSA will utilize Public Health’s policy if they fund
subrecipients in the future. |
48 |
| Preventive Health and Health Services Block Grant
funded solely with Prevention and Public Health
Funds |
Subrecipient Monitoring. The Chronic Disease Control Branch
(Branch) of Public Health and EMSA did not communicate the
universal identifier and system for award management
requirements to applicants in accordance with 2 CFR 25.200. The
unique entry identifier was not collected prior to awarding funds
and the Public Health and EMSA did not communicate to their
subrecipients the required federal award data elements upon
making a subaward. |
2015-16 |
| Partially Corrected. In approximately January 2017, the Branch
reviewed all federal statutes, regulations, and the terms and
conditions of the federal award to determine whether policies and
procedures existed and were operating effectively to ensure
compliance with all requirements. The Branch determined
policies and procedures needed to be developed.
On February 24, 2017, the Branch distributed a Memorandum of
Understanding (MOU) to Public Health programs and EMSA that
identified the requirements for ensuring the required information
is communicated to applicants in accordance with 2 CFR 25.200
and 2 CFR 331 and that the unique identifier is collected prior to
making subawards in accordance with 2 CFR 25.205.
Each Public Health program and EMSA were required to sign the
MOU acknowledging receipt and to confirm their understanding
of the terms.
On July 14, 2017, the Branch hosted a Preventive Health and
Health Services Block Grant (PHHSBG) orientation and provided
additional guidance on the requirement to obtain the unique
identifier prior to awarding funds and for communicating the
required federal award information to subrecipients timely. The
Branch allowed Public Health and EMSA staff to ask questions or
request additional clarification.
On August 4, 2017, the Branch issued a reminder on the
requirement to obtain the unique identifier prior to awarding funds
and for communicating the required federal award information to
subrecipients timely.
In November 2017, the Branch created and distributed a “Program
Instructions for Potential PHHSBG Contractors and Subrecipients
Checklist” to all Public Health programs and EMSA. The Branch
continuously collects, files, and maintains completed checklists to
demonstrate compliance with this requirement.
EMSA adopted Public Health’s policies and procedures to ensure
that the requirement to obtain the unique identifier prior to
awarding funds and for communicating the required federal award
information is met in a timely manner. |
44 |
| Preventive Health and Health Services Block Grant
funded solely with Prevention and Public Health
Funds |
Subrecipient Monitoring. The Chronic Disease Control Branch
(Branch) of Public Health did not perform sufficient monitoring
activities to determine that subrecipients' use of funds is in
accordance with federal statutes, regulations, and the terms and
conditions of the subaward. |
2016-17 |
| Partially Corrected. In April – June 2018, the Branch reviewed all
federal statutes, regulations, and the terms and conditions of the
federal Preventive Health and Health Services Block Grant
(PHHSBG) award to identify the necessary components of the
subrecipient monitoring process, during the subaward period.
The Branch also developed comprehensive subrecipient policies
and procedures for utilization during the subaward period. The
policies and procedures include provisions for the review of
subrecipient compliance with federal statutes, regulations, and the
terms and conditions of the subaward; and that the subawardee
achieves its performance goals.
The Branch will continue working with Public Health’s Office of
Compliance/Internal Audits to develop a comprehensive during the-award monitoring tool. The Branch will distribute a revised
during-the-award subrecipient monitoring tool to Public Health
programs, if necessary.
The Branch will follow up with Public Health programs to ensure
they complete the subrecipient monitoring tool for each
subrecipient.
The Branch will collect, file, and maintain completed monitoring
tools to demonstrate compliance with these requirements.
The Branch will revise the comprehensive subrecipient during the-award policies and procedures, if necessary. |
42 |
