Central Fiscal Compliance Monitoring

Multnomah County primarily utilizes two monitoring tools in complying with its subcontractor and subrecipient monitoring responsibilities.  These tools include annual financial statement analyses and onsite fiscal compliance reviews.   Subcontractors and subrecipients with individual contracts of $75,000 or greater are generally selected for onsite reviews.  Departments and divisions can also direct or request onsite fiscal reviews be performed for certain subcontractors or subrecipients regardless of the contract dollar amount.  Onsite reviews include a risk assessment, management inquiry, and substantive testing of the organization’s fiscal policies, procedures, general ledger transactions, and balance sheet transactions.  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.
• Verify compliance with payroll taxing authorities
• Inclusion of required topics in written financial policies and procedures

Subcontractor and 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 A-133 and Compliance Supplement
• OMB Circular A-122
• OMB Circular A-87
• OMB Circular A-21
• OMB Circular A-102
• Government Auditing Standards
• 45CFR or OMB Circular A-110 (For-profit entities only)
• FAR31.2 (For-profit entities only)
• Contract specific attachments and special conditions

Department Fiscal Monitoring:

Certain County Departments have assumed fiscal monitoring responsibilities for their subrecipients.  As such the Department’s procedures performed are specific to the requirements stated in each federally funded grant and contract.