Agenda - 08-01-2022; 1 - Ratification of the County Manager's Approval of ARPA Policies

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59 Report review: A subrecipient must submit quarterly financial and performance reports, based on the schedule set forth in the subaward.The nature and scope of the reports will depend on the project and be spelled out in the subaward.The reports will be reviewed by the Chief Financial Officer.Any deficiencies or other performance concerns will be addressed with the subrecipient in a timely manner and could trigger additional monitoring requirements or other interventions, as specified in the subaward. Desk review:The County will conduct a meeting to review the subrecipient's award administration capacity and financial management.The meeting may be held virtually or in person. Topics covered will depend on project scope and subrecipient risk assessment and may include governance, budgeting, accounting, internal controls, conflict of interest, personnel, procurement, inventory, and record keeping.The County will produce a report which summarizes the results and any corrective actions if deemed necessary.The report will be shared in a timely manner with the subrecipient. Onsite review:The County will conduct an on-site meeting at the subrecipient's location to review the subrecipient's project performance and compliance.Topics covered will depend on project scope and subrecipient risk assessment and may include project procurement, data systems, activity and performance tracking, project reporting, inventory, and software systems. The County will produce a report which summarizes the results and any corrective actions deemed necessary.The report will be shared in a timely manner with the subrecipient. Audit review:The County must verify that every subrecipient is audited as required by 2 CFR 200 Subpart F (Single Audit) when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in 2 CFR 200.501.The County must obtain a copy of the subrecipient's Single Audit from the Federal Audit Clearinghouse (FAC). Within six months of the acceptance of the audit report by the FAC, the County will issue a management decision for any audit findings related to the subaward.The decision will clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action. (The decision will include reference numbers the auditor assigned to each finding.)The decision will provide a timetable for responsive actions by the subrecipient. Prior to issuing the management decision,the County may request additional information or documentation from the auditee, including a request for auditor assurance related to the documentation, as a way of mitigating disallowed costs. Procedures engagement: Applicable only to subrecipients who are not subject to the Single Audit Act.An auditor will perform specific procedures and report on findings.The scope must be limited to the following compliance requirements: activities allowed or unallowed; allowable costs/cost principles; eligibility; and reporting.The review will be arranged and paid for by the County.The County will verify completion of the procedures engagement. Within six months of the acceptance of the procedures engagement report,the County will issue a management decision for any findings related to the subaward.The decision will provide a timetable for responsive actions by the subrecipient. Prior to issuing the management decision, the County may request additional information or documentation from the subrecipient, including a request for auditor assurance related to the documentation, as a way of mitigating disallowed costs. 7 of 39