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prescribed that, for subrecipients receiving less Internal Systems Used to Track Financial than $500,000 in federal funds passed through from Audit Findings KYTC, the agency must determine if the amount of The 2008 training also established a tracking federal funds received from all federal sources met system to ensure OMB Circular A-133 compliance. the threshold. The tracking system was a second spreadsheet with KYTC agencies were directed by the Office of the following column headings: Audit to send a letter to each subrecipient request- ing that it agree to provide a copy of its OMB Circu- 1. Subrecipient Name lar A-133 audit to KYTC or certify to KYTC that its 2. Date of Audit Request Letter federal expenditures did not exceed $500,000. The 3. Date Audit or Certification Received 2008 guidance contained a sample form to be returned 4. Date Audit Sent to IAB for Review to the appropriate KYTC agency by September 15th 5. Date Memo Received from IAB each year. 6. Date Request Sent to Subrecipient for Cor- The guidance specified the following timeline rective Action Plan* for completion of tasks regarding the review of audit 7. Date of Corrective Action Plan Implementa- reports: tion Verification* 8.Notification to Chief Audit Executive Regard- Date: Task: ing Noncompliance* June 30 End of fiscal year. *If applicable September 1 Request audit or certification from subrecipient. The 2008 training concluded by advising KYTC March 30 Audit must be completed agencies, including the OTD, of the following re- and received by KYTC. sponsibilities for assuring compliance with OMB April 15 Follow-up for missing audits. Circular A-133 requirements: Upon receipt Forward audit to Internal Audit · Disclose to subrecipients the source of federal Branch (IAB). funds in contracts and agreements, including Upon receipt Review IAB's desk review com- ­­ CFDA title and number, ments memorandum. ­­ Award name and number, After IAB review Request corrective action plan, if ­­ Award year, and necessary. ­­ Name of awarding federal agency. 90 days later Ensure corrective action plan was · Cite applicable federal laws and regulations in implemented. contracts and any supplemental agreements. The timeline included a note that, if a subrecipient's · Monitor subrecipients through site visits, re- fiscal year ended on December 31, all task dates ports, and correspondence. would be moved forward by 6 months. · Comply with OMB Circular A-133 audit re- Following a desk review of the OMB Cir cular quirements for subrecipients spending more A-133 audit, the Manager of IAB was to send a mem- than $500,000 in total federal awards. orandum to the head of the appropriate agency. (A · Document, document, document. copy of the memo appears in the 2008 document referenced below.) The memo states that the audit The Oregon DOT has been reviewed for compliance with Generally Accepted Government Auditing Standards (GAGAS) The Governor of Oregon has designated the Or- and notes the amount of federal funds KYTC passed egon DOT as the agency responsible for administer- through to the subrecipient. The mem orandum ing state and FTA public transportation programs. describes if there were any reportable findings or Within the Oregon DOT, the Public Transit Divi- instances of non-compliance. The memorandum also sion (PTD) is responsible for administering approx- identifies the certified public accounting (CPA) firm imately $60 million annually in FTA funding and that conducted the subrecipient audit and whether the nearly $10 million in state funding for public tran- CPA firm received an unqualified opinion during its sit. PTD's management team consists of the division most recent quality control review. administrator, who reports to the operations deputy 13