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57 <br /> IV. ASSESSMENT OF RISK <br /> Before engaging in a subaward,the County must evaluate a subrecipient's risk of noncompliance with <br /> Federal statutes, regulations, and the terms and conditions of the subaward to determine whether to <br /> award the subaward and the appropriate subrecipient monitoring. <br /> The Chief Financial Officer will conduct the risk assessment, which will include consideration of the <br /> following factors: <br /> (1)The subrecipient's prior experience with the same or similar subawards; <br /> (2)The results of previous audits including whether or not the subrecipient receives a Single <br /> Audit in accordance with 2 CFR 200 Subpart F and the extent to which the same or similar <br /> subaward has been audited as a major program; <br /> (3)Whether the subrecipient has new personnel or new or substantially changed systems; and <br /> (4)The extent and results of Federal awarding agency monitoring (e.g., if the subrecipient also <br /> receives Federal awards directly from a Federal awarding agency). 2 CFR 200.332(b). <br /> The results of the risk assessment must be documented in the Subrecipient Assessment of Risk form in <br /> Appendix 2 and will be used to dictate the types and degree of subrecipient monitoring. (Appendix 2: <br /> Subrecipient Assessment of Risk)The County will assign an overall risk level to the subrecipient <br /> indicating the following: <br /> Low Risk Moderate Risk High Risk <br /> There is a low risk that the There is moderate risk that the There is high risk that the <br /> subrecipient will fail to meet subrecipient will fail to meet subrecipient will fail to meet <br /> project or programmatic project or programmatic project or programmatic <br /> objectives or incur significant objectives or incur significant objectives or incur significant <br /> deficiencies in financial, deficiencies in financial, deficiencies in financial, <br /> regulatory, reporting, or other regulatory, reporting, or other regulatory, reporting, or other <br /> compliance requirements. compliance requirements. compliance requirements. <br /> If a proposed subrecipient is deemed high risk,the Chief Financial Officer must provide written <br /> justification to proceed with the subaward.The justification must be approved by the Orange County <br /> Attorney. <br /> V. SUBRECIPIENT MONITORING <br /> The County will develop and implement a subrecipient monitoring plan for the particular subaward <br /> based on the findings of the Subrecipient Assessment of Risk.According to 2 CFR 200.332(d), the <br /> monitoring plan must involve: <br /> (1) Reviewing financial and performance reports required by the pass-through entity. <br /> (2) Following-up and ensuring that the subrecipient takes timely and appropriate action on all <br /> deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through <br /> entity detected through audits, on-site reviews, and written confirmation from the subrecipient, <br /> highlighting the status of actions planned or taken to address Single Audit findings related to the <br /> particular subaward. <br /> 5 of 39 <br />