Noncompliance and Significant Deficiency in Internal Controls over Compliance for Reporting
Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518.
Criteria: Appendix A to Part 170 of Title 2 CFR, Subtitle A, Chapter 1 describes the first-tier subaward reporting requirements under the Federal Funding Accountability and Transparency Act (FFATA), which requires prime recipients to report first-tier subawards to non-Federal entities equal to or exceeding $30,000 within 30 days.
Condition: The Organization failed to report its first-tier subawards subject to FFATA requirements within the 30 day period.
Cause: A breakdown in the Organization’s internal controls over reporting did not allow the Organization to meet the reporting requirements of the program.
Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from complying with the reporting requirements of the program.
Identification of a Repeat Finding: New finding.
Recommendation: The Organization should review its system of internal controls over reporting to determine improvements that can be made to ensure the Organization actively tracks and adheres to reporting requirements outlined in its award agreements and included in the CFR.
Views of Responsible Officials: The Organization was not aware of the FFATA reporting requirements. The Organization has reviewed FFATA reporting requirements and has adopted a procedure to ensure such reporting is completed as required.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Subrecipient Monitoring
Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518.
Criteria: Title 2 CFR §200.332 describes subrecipient monitoring requirements for pass-through entities, which include the requirement that pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes but is not limited to:
• Subrecipient name (which must match the name associated with its unique entity identifier);
• Subrecipient's unique entity identifier;
• Federal Award Identification Number (FAIN);
• Subaward Period of Performance Start and End Date;
• Subaward Budget Period Start and End Date;
• Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation;
• Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
• Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA);
• Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity;
• Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement;
• Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414.
• All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award;
• Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports;
• A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and
• Appropriate terms and conditions concerning closeout of the subaward.
Condition: The Organization did not have a process of generating a subaward agreement that was in compliance with the criteria listed above.
Cause: A breakdown in the Organization’s internal controls over subrecipient monitoring did not allow the Organization to fully meet the subrecipient monitoring requirements under the program.
Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from fully complying with the subrecipient monitoring requirements of the program.
Identification of a Repeat Finding: New finding.
Recommendation: The Organization should review its system of internal control over subrecipient monitoring to determine improvements that can be made to ensure the Organization has agreements that meet the required criteria identified above.
Views of Responsible Officials: The Organization misunderstood the directions given by the Grants Management Specialist in this instance. The Organization has reviewed the requirements of Compliance for Subrecipient Monitoring and has controls in place to ensure those requirements are followed.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Cash Management
Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518.
Criteria: Title 2 CFR §200.305 establishes the criteria for cash management requirements for states and non-Federal entities other than states. This includes non-Federal entities utilizing the reimbursement method and requires that expenditures were incurred prior to the date of the reimbursement request.
Condition: The Organization drew funds before expenditures were incurred.
Cause: A breakdown in the Organization’s internal controls over cash management did not allow the Organization to meet the reporting requirements of the program.
Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from complying with the cash management requirements of the program.
Identification of a Repeat Finding: New finding.
Recommendation: The Organization should review its system of internal control over cash management to determine improvements that can be made to ensure the Organization has processes for remaining in compliance with all cash management criteria identified above.
Views of Responsible Officials: The Organization misunderstood the directions given by the Grants Management Specialist in this instance. The Organization has reviewed the requirements of Compliance for Cash Management and has controls in place to ensure those requirements are followed.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Reporting
Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518.
Criteria: Appendix A to Part 170 of Title 2 CFR, Subtitle A, Chapter 1 describes the first-tier subaward reporting requirements under the Federal Funding Accountability and Transparency Act (FFATA), which requires prime recipients to report first-tier subawards to non-Federal entities equal to or exceeding $30,000 within 30 days.
Condition: The Organization failed to report its first-tier subawards subject to FFATA requirements within the 30 day period.
Cause: A breakdown in the Organization’s internal controls over reporting did not allow the Organization to meet the reporting requirements of the program.
Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from complying with the reporting requirements of the program.
Identification of a Repeat Finding: New finding.
Recommendation: The Organization should review its system of internal controls over reporting to determine improvements that can be made to ensure the Organization actively tracks and adheres to reporting requirements outlined in its award agreements and included in the CFR.
Views of Responsible Officials: The Organization was not aware of the FFATA reporting requirements. The Organization has reviewed FFATA reporting requirements and has adopted a procedure to ensure such reporting is completed as required.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Subrecipient Monitoring
Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518.
Criteria: Title 2 CFR §200.332 describes subrecipient monitoring requirements for pass-through entities, which include the requirement that pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes but is not limited to:
• Subrecipient name (which must match the name associated with its unique entity identifier);
• Subrecipient's unique entity identifier;
• Federal Award Identification Number (FAIN);
• Subaward Period of Performance Start and End Date;
• Subaward Budget Period Start and End Date;
• Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation;
• Total Amount of the Federal Award committed to the subrecipient by the pass-through entity;
• Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA);
• Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity;
• Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement;
• Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414.
• All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award;
• Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports;
• A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and
• Appropriate terms and conditions concerning closeout of the subaward.
Condition: The Organization did not have a process of generating a subaward agreement that was in compliance with the criteria listed above.
Cause: A breakdown in the Organization’s internal controls over subrecipient monitoring did not allow the Organization to fully meet the subrecipient monitoring requirements under the program.
Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from fully complying with the subrecipient monitoring requirements of the program.
Identification of a Repeat Finding: New finding.
Recommendation: The Organization should review its system of internal control over subrecipient monitoring to determine improvements that can be made to ensure the Organization has agreements that meet the required criteria identified above.
Views of Responsible Officials: The Organization misunderstood the directions given by the Grants Management Specialist in this instance. The Organization has reviewed the requirements of Compliance for Subrecipient Monitoring and has controls in place to ensure those requirements are followed.
Noncompliance and Significant Deficiency in Internal Controls over Compliance for Cash Management
Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518.
Criteria: Title 2 CFR §200.305 establishes the criteria for cash management requirements for states and non-Federal entities other than states. This includes non-Federal entities utilizing the reimbursement method and requires that expenditures were incurred prior to the date of the reimbursement request.
Condition: The Organization drew funds before expenditures were incurred.
Cause: A breakdown in the Organization’s internal controls over cash management did not allow the Organization to meet the reporting requirements of the program.
Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from complying with the cash management requirements of the program.
Identification of a Repeat Finding: New finding.
Recommendation: The Organization should review its system of internal control over cash management to determine improvements that can be made to ensure the Organization has processes for remaining in compliance with all cash management criteria identified above.
Views of Responsible Officials: The Organization misunderstood the directions given by the Grants Management Specialist in this instance. The Organization has reviewed the requirements of Compliance for Cash Management and has controls in place to ensure those requirements are followed.