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Agenda - 08-01-2022; 1 - Ratification of the County Manager's Approval of ARPA Policies
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Agenda - 08-01-2022; 1 - Ratification of the County Manager's Approval of ARPA Policies
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8/1/2022
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Special Meeting
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Agenda
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58 <br /> (3) Issuing a management decision for applicable audit findings pertaining only to the Federal <br /> award provided to the subrecipient from the pass-through entity as required by 2 CFR 200.521. <br /> (4)The pass-through entity is responsible for resolving audit findings specifically related to the <br /> subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current <br /> Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been <br /> excluded from receipt of Federal funding(e.g., has been debarred or suspended),the pass- <br /> through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight <br /> agency to perform audit follow-up and make management decisions related to cross-cutting <br /> findings in accordance with section 2 CFR 200.513(a)(3)(vii). Such reliance does not eliminate the <br /> responsibility of the pass-through entity to issue subawards that conform to agency and award- <br /> specific requirements,to manage risk through ongoing subaward monitoring, and to monitor <br /> the status of the findings that are specifically related to the subaward. <br /> The County's monitoring plan will vary based on the overall subrecipient risk assessment as low risk, <br /> medium risk, or high risk, detailed as follows: <br /> Subrecipient Deemed Low Risk Subrecipient Deemed Medium Subrecipient Deemed High Risk <br /> Risk <br /> • Payment validations • More detailed financial • More detailed financial <br /> (monthly) reporting reporting <br /> • Report reviews (quarterly) • Payment validations • Compliance training (one- <br /> Desk reviews (at least once (monthly) time) <br /> per year and more • Report reviews (bi-monthly) • Prior approvals for certain <br /> frequently if requested by • Desk reviews (within 6 expenditures <br /> County or subrecipient) months of project start and • Payment validations <br /> • Onsite reviews (upon every six months (monthly) <br /> request of County or thereafter) • Report reviews (monthly) <br /> subrecipient) • Onsite reviews (within 12 • Desk reviews (within 3 <br /> • Audit review (yearly) months of project start and months of project start and <br /> annually thereafter, or at least quarterly <br /> more frequently as thereafter) <br /> requested by County or . Onsite reviews (within 6 <br /> subrecipient) months of project start and <br /> • Audit review (yearly) bi-annually thereafter, or <br /> • Procedures engagement (if more frequently as <br /> subrecipient not subject to requested by County or <br /> Single Audit Act; yearly) subrecipient) <br /> • Audit review(yearly) <br /> • Procedures engagement(if <br /> subrecipient not subject to <br /> Single Audit Act; yearly) <br /> Payment validation:All subrecipient documentation for project expenditures must be reviewed <br /> by the County for compliance with subaward requirements. Any non-compliant expenditures <br /> will be denied and the subrecipient will be provided a reasonable description of the reason for <br /> denial and an opportunity to cure the deficiency. For a subrecipient on a reimbursement-based <br /> payment structure,the validation will occur before a reimbursement payment is approved. For a <br /> subrecipient that received an up-front payment, any funds found to have been expended in <br /> violation of the subaward requirements must be repaid to the County. <br /> 6 of 39 <br />
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