Central Fiscal Compliance Monitoring

Multnomah County primarily utilizes four monitoring tools in complying with its subrecipient monitoring responsibilities.  These tools include annual financial statement analysis, financial risk assessments, management inquiries, and onsite fiscal compliance reviews. Subrecipients are selected for monitoring based on risk. Subrecipients of federal funding, regardless of amount, are included in the onsite review population.  Departments and divisions may also direct or request on site fiscal reviews be performed for certain subcontractors or subrecipients regardless of the contract dollar amount.  Onsite reviews include review of fiscal policies and procedures for compliance with funding source requirements, substantive testing of the organization’s primary transaction cycles (revenue, disbursements, and payroll) and inquiry with management.  Major areas of review include:

  • Fiscal requirements related to specific contract conditions

  • Applicable Federal and State rules and regulations

  • Appropriate chart of accounts, general ledger, and financial reporting

  • Accurate and complete property management records for all capital assets and related depreciation

  • Adequacy of required minimum accounting records for all major transaction cycles (revenue, general disbursements, and payroll)

  • Verification that internal controls are operating as expected

  • Payroll expense and personnel records include required documentation related to time, program, rate, and eligibility to work in the United States

  • Verification of compliance with payroll taxing authorities

  • Inclusion of required topics in written financial policies and procedures

Subrecipient accounting practices are measured against County documents, all applicable Federal and State rules and regulations as well as the following authoritative accounting pronouncements:

  • Generally Accepted Accounting Principles

  • Generally Accepted Auditing Standards

  • Applicable AICPA Industry Audit and Accounting Guides

  • OMB Circular 2 CRF 200

  • Government Auditing Standards

  • FAR31.2 (For-profit entities only)

  • Contract specific attachments and special conditions

The County also contracts with hospitals, educational institutions, and other agencies related to governmental units.  Review procedures for these organizations are limited to the analysis of their audited financial statements and Single Audit, if applicable.  Due to significant oversight and a high level monitoring performed by other regulatory bodies, additional monitoring at the County level has been deemed unnecessary.  If additional monitoring be deemed necessary for these organizations, the County has the ability to respond accordingly.

Timing of County reviews are generally noted below:

  • Financial statement analyses – Annually, upon receipt of statements

  • Site reviews – Rotation, given adequate staffing, every 1-3 years based on "score" received by last site review

Risk Assessments

Risk assessments are required in the process of awarding and sub-awarding of federal dollars. They assist awarding entities in determining the level of monitoring required of any given subrecipient based on the risk. A current risk assessment must be in place prior to executing any subrecipient agreement or amendment. Risk assessments are valid for one year from date of completion.  Risk assessments are performed in the following way:

        Pre-Award - Departments are responsible for initiating pre-award risk assessment requests in advance of contract execution.

        Standard - During the course of performing fiscal compliance site reviews, Fiscal Compliance will also perform a standard risk assessment of each subrecipient.

The purpose of the risk assessment is threefold:

  • To assist in determining whether a subrecipient contract should include additional language due to a high fiscal risk determination.

  • To assist Fiscal Compliance in determining the appropriate level and frequency of fiscal monitoring activity.

  • To serve, for audit purposes, as part of the required documentary evidence of monitoring throughout the lifecycle of a subrecipient agreement.

Manual

Countywide Contractor's Fiscal Policies & Procedures Manual (127.04 KB)