Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-002 – Procurement and Suspension and Debarment
Identification of the federal program:
Federal Agency:
Department of Health and Human Services – Centers for Disease Control and Prevention
United States Department of State
Assistance Listing:
93.U02 – National Health Initiatives, Strategies and Action Plans for Infectious Diseases
19.415 – Professional and Cultural Exchange Programs – Citizen Exchanges
Federal Award Identification Number:
93.U02 – HHSD2002015M88157B – 75D30120F08105
19.415 – SECAGD22CA0060
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the FederalFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 84
Section III – Federal Award Findings and Questioned Costs (continued)
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”
Condition:
During our testing of procurement and suspension and debarment compliance requirements we
noted the following:
• Under 93.U02, we noted for 5 transactions out of 25 tested, FHI 360 relied on the screening
for suspension and debarment performed by a third-party service provider without having
any additional control to validate that these specific vendors were part of the screening
performed by the third-party service provider in their continuous monitoring procedures.
• Under 19.415, we noted for 1 transaction out of 25 samples tested, FHI 360 did not perform
the screening of the vendor prior to setting up the vendor in the system and executing the
contract.
Cause:
Under 93.U02, FHI 360 performed suspension and debarment checks in prior periods and therefore
relied on the “continuous monitoring” performed by its third-party service provider to monitor the
suspension and debarment status. Under 19.415, FHI 360 performed suspension and debarment
check after setting up the vendor in the system and executing the contract.
Effect or Potential Effect:
Under 93.U02, In the absence of having additional controls in place to verify and validate that the
continuous monitoring performed by the third-party service provider includes all vendors and
suppliers, FHI 360 could potentially contract with a vendor who is suspended or debarred and not
detect the non-compliance timely. Similarly, under 19.415, FHI 360 could execute a contract with
a vendor who is suspended or debarred.
Questioned costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 85
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
FHI 360 internally performs suspension and debarment checks of its vendors and suppliers. FHI
360 also utilizes a third-party service provider to perform continuous monitoring of its vendors
and suppliers for suspension and debarment and receives a daily monitoring report. Although, FHI
360 received a daily monitoring report from the service provider that showed there were no
matches for vendors enrolled throughout the fiscal period, the third-party service provider does
not have a SOC 1 report and there were no additional controls FHI implemented to rely on the
completeness of the results provided by the third-party service provider.
The total amount of procurement transactions subject to suspension and debarment screening
under 19.415 for FY 2023 is $1,154,561. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $4,981,200.
The total amount of procurement transactions subject to suspension and debarment screening
under 93.U02 for FY 2023 is $3,3319,092. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $9,160,477.
Identification as a Repeat Finding:
This is not a repeat finding from prior year.
Recommendation:
We recommend FHI 360 monitor new vendor set up in the system and ensure the screening for
suspension and debarment is performed prior to executing a contract with a vendor.
We recommend FHI 360 implement additional validation controls, when relying on continuous
monitoring for suspension and debarment checks performed by any third-party service provider.Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 86
Section III – Federal Award Findings and Questioned Costs (continued)
Views of Responsible Officials:
Management will reemphasize its established policies and procedures around the restricted party
screenings’ (RPS) importance highlighting the timeliness component of when the RPS is required.
Management will implement additional controls to ensure the suite of controls around its use of
the third party service provider adequately minimizes any related risks. Specifically, we will
periodically perform RPS via the service provider and the source databases to confirm results are
the same. We will also periodically compare the complete list of active vendors within our internal
vendor management systems reconciles to the list of vendors within the service provider where we
are relying on continuous monitoring.
Finding 2023-002 – Procurement and Suspension and Debarment
Identification of the federal program:
Federal Agency:
Department of Health and Human Services – Centers for Disease Control and Prevention
United States Department of State
Assistance Listing:
93.U02 – National Health Initiatives, Strategies and Action Plans for Infectious Diseases
19.415 – Professional and Cultural Exchange Programs – Citizen Exchanges
Federal Award Identification Number:
93.U02 – HHSD2002015M88157B – 75D30120F08105
19.415 – SECAGD22CA0060
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the FederalFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 84
Section III – Federal Award Findings and Questioned Costs (continued)
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”
Condition:
During our testing of procurement and suspension and debarment compliance requirements we
noted the following:
• Under 93.U02, we noted for 5 transactions out of 25 tested, FHI 360 relied on the screening
for suspension and debarment performed by a third-party service provider without having
any additional control to validate that these specific vendors were part of the screening
performed by the third-party service provider in their continuous monitoring procedures.
• Under 19.415, we noted for 1 transaction out of 25 samples tested, FHI 360 did not perform
the screening of the vendor prior to setting up the vendor in the system and executing the
contract.
Cause:
Under 93.U02, FHI 360 performed suspension and debarment checks in prior periods and therefore
relied on the “continuous monitoring” performed by its third-party service provider to monitor the
suspension and debarment status. Under 19.415, FHI 360 performed suspension and debarment
check after setting up the vendor in the system and executing the contract.
Effect or Potential Effect:
Under 93.U02, In the absence of having additional controls in place to verify and validate that the
continuous monitoring performed by the third-party service provider includes all vendors and
suppliers, FHI 360 could potentially contract with a vendor who is suspended or debarred and not
detect the non-compliance timely. Similarly, under 19.415, FHI 360 could execute a contract with
a vendor who is suspended or debarred.
Questioned costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 85
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
FHI 360 internally performs suspension and debarment checks of its vendors and suppliers. FHI
360 also utilizes a third-party service provider to perform continuous monitoring of its vendors
and suppliers for suspension and debarment and receives a daily monitoring report. Although, FHI
360 received a daily monitoring report from the service provider that showed there were no
matches for vendors enrolled throughout the fiscal period, the third-party service provider does
not have a SOC 1 report and there were no additional controls FHI implemented to rely on the
completeness of the results provided by the third-party service provider.
The total amount of procurement transactions subject to suspension and debarment screening
under 19.415 for FY 2023 is $1,154,561. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $4,981,200.
The total amount of procurement transactions subject to suspension and debarment screening
under 93.U02 for FY 2023 is $3,3319,092. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $9,160,477.
Identification as a Repeat Finding:
This is not a repeat finding from prior year.
Recommendation:
We recommend FHI 360 monitor new vendor set up in the system and ensure the screening for
suspension and debarment is performed prior to executing a contract with a vendor.
We recommend FHI 360 implement additional validation controls, when relying on continuous
monitoring for suspension and debarment checks performed by any third-party service provider.Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 86
Section III – Federal Award Findings and Questioned Costs (continued)
Views of Responsible Officials:
Management will reemphasize its established policies and procedures around the restricted party
screenings’ (RPS) importance highlighting the timeliness component of when the RPS is required.
Management will implement additional controls to ensure the suite of controls around its use of
the third party service provider adequately minimizes any related risks. Specifically, we will
periodically perform RPS via the service provider and the source databases to confirm results are
the same. We will also periodically compare the complete list of active vendors within our internal
vendor management systems reconciles to the list of vendors within the service provider where we
are relying on continuous monitoring.
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-002 – Procurement and Suspension and Debarment
Identification of the federal program:
Federal Agency:
Department of Health and Human Services – Centers for Disease Control and Prevention
United States Department of State
Assistance Listing:
93.U02 – National Health Initiatives, Strategies and Action Plans for Infectious Diseases
19.415 – Professional and Cultural Exchange Programs – Citizen Exchanges
Federal Award Identification Number:
93.U02 – HHSD2002015M88157B – 75D30120F08105
19.415 – SECAGD22CA0060
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the FederalFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 84
Section III – Federal Award Findings and Questioned Costs (continued)
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”
Condition:
During our testing of procurement and suspension and debarment compliance requirements we
noted the following:
• Under 93.U02, we noted for 5 transactions out of 25 tested, FHI 360 relied on the screening
for suspension and debarment performed by a third-party service provider without having
any additional control to validate that these specific vendors were part of the screening
performed by the third-party service provider in their continuous monitoring procedures.
• Under 19.415, we noted for 1 transaction out of 25 samples tested, FHI 360 did not perform
the screening of the vendor prior to setting up the vendor in the system and executing the
contract.
Cause:
Under 93.U02, FHI 360 performed suspension and debarment checks in prior periods and therefore
relied on the “continuous monitoring” performed by its third-party service provider to monitor the
suspension and debarment status. Under 19.415, FHI 360 performed suspension and debarment
check after setting up the vendor in the system and executing the contract.
Effect or Potential Effect:
Under 93.U02, In the absence of having additional controls in place to verify and validate that the
continuous monitoring performed by the third-party service provider includes all vendors and
suppliers, FHI 360 could potentially contract with a vendor who is suspended or debarred and not
detect the non-compliance timely. Similarly, under 19.415, FHI 360 could execute a contract with
a vendor who is suspended or debarred.
Questioned costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 85
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
FHI 360 internally performs suspension and debarment checks of its vendors and suppliers. FHI
360 also utilizes a third-party service provider to perform continuous monitoring of its vendors
and suppliers for suspension and debarment and receives a daily monitoring report. Although, FHI
360 received a daily monitoring report from the service provider that showed there were no
matches for vendors enrolled throughout the fiscal period, the third-party service provider does
not have a SOC 1 report and there were no additional controls FHI implemented to rely on the
completeness of the results provided by the third-party service provider.
The total amount of procurement transactions subject to suspension and debarment screening
under 19.415 for FY 2023 is $1,154,561. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $4,981,200.
The total amount of procurement transactions subject to suspension and debarment screening
under 93.U02 for FY 2023 is $3,3319,092. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $9,160,477.
Identification as a Repeat Finding:
This is not a repeat finding from prior year.
Recommendation:
We recommend FHI 360 monitor new vendor set up in the system and ensure the screening for
suspension and debarment is performed prior to executing a contract with a vendor.
We recommend FHI 360 implement additional validation controls, when relying on continuous
monitoring for suspension and debarment checks performed by any third-party service provider.Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 86
Section III – Federal Award Findings and Questioned Costs (continued)
Views of Responsible Officials:
Management will reemphasize its established policies and procedures around the restricted party
screenings’ (RPS) importance highlighting the timeliness component of when the RPS is required.
Management will implement additional controls to ensure the suite of controls around its use of
the third party service provider adequately minimizes any related risks. Specifically, we will
periodically perform RPS via the service provider and the source databases to confirm results are
the same. We will also periodically compare the complete list of active vendors within our internal
vendor management systems reconciles to the list of vendors within the service provider where we
are relying on continuous monitoring.
Finding 2023-002 – Procurement and Suspension and Debarment
Identification of the federal program:
Federal Agency:
Department of Health and Human Services – Centers for Disease Control and Prevention
United States Department of State
Assistance Listing:
93.U02 – National Health Initiatives, Strategies and Action Plans for Infectious Diseases
19.415 – Professional and Cultural Exchange Programs – Citizen Exchanges
Federal Award Identification Number:
93.U02 – HHSD2002015M88157B – 75D30120F08105
19.415 – SECAGD22CA0060
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the FederalFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 84
Section III – Federal Award Findings and Questioned Costs (continued)
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”
Condition:
During our testing of procurement and suspension and debarment compliance requirements we
noted the following:
• Under 93.U02, we noted for 5 transactions out of 25 tested, FHI 360 relied on the screening
for suspension and debarment performed by a third-party service provider without having
any additional control to validate that these specific vendors were part of the screening
performed by the third-party service provider in their continuous monitoring procedures.
• Under 19.415, we noted for 1 transaction out of 25 samples tested, FHI 360 did not perform
the screening of the vendor prior to setting up the vendor in the system and executing the
contract.
Cause:
Under 93.U02, FHI 360 performed suspension and debarment checks in prior periods and therefore
relied on the “continuous monitoring” performed by its third-party service provider to monitor the
suspension and debarment status. Under 19.415, FHI 360 performed suspension and debarment
check after setting up the vendor in the system and executing the contract.
Effect or Potential Effect:
Under 93.U02, In the absence of having additional controls in place to verify and validate that the
continuous monitoring performed by the third-party service provider includes all vendors and
suppliers, FHI 360 could potentially contract with a vendor who is suspended or debarred and not
detect the non-compliance timely. Similarly, under 19.415, FHI 360 could execute a contract with
a vendor who is suspended or debarred.
Questioned costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 85
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
FHI 360 internally performs suspension and debarment checks of its vendors and suppliers. FHI
360 also utilizes a third-party service provider to perform continuous monitoring of its vendors
and suppliers for suspension and debarment and receives a daily monitoring report. Although, FHI
360 received a daily monitoring report from the service provider that showed there were no
matches for vendors enrolled throughout the fiscal period, the third-party service provider does
not have a SOC 1 report and there were no additional controls FHI implemented to rely on the
completeness of the results provided by the third-party service provider.
The total amount of procurement transactions subject to suspension and debarment screening
under 19.415 for FY 2023 is $1,154,561. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $4,981,200.
The total amount of procurement transactions subject to suspension and debarment screening
under 93.U02 for FY 2023 is $3,3319,092. Total expenditures reported on the Schedule of
Expenditures of Federal Awards is $9,160,477.
Identification as a Repeat Finding:
This is not a repeat finding from prior year.
Recommendation:
We recommend FHI 360 monitor new vendor set up in the system and ensure the screening for
suspension and debarment is performed prior to executing a contract with a vendor.
We recommend FHI 360 implement additional validation controls, when relying on continuous
monitoring for suspension and debarment checks performed by any third-party service provider.Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 86
Section III – Federal Award Findings and Questioned Costs (continued)
Views of Responsible Officials:
Management will reemphasize its established policies and procedures around the restricted party
screenings’ (RPS) importance highlighting the timeliness component of when the RPS is required.
Management will implement additional controls to ensure the suite of controls around its use of
the third party service provider adequately minimizes any related risks. Specifically, we will
periodically perform RPS via the service provider and the source databases to confirm results are
the same. We will also periodically compare the complete list of active vendors within our internal
vendor management systems reconciles to the list of vendors within the service provider where we
are relying on continuous monitoring.
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented
Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act
(FFATA)
Identification of the federal program:
Federal Agency: United States Agency for International Development
Assistance Listing:
98.001 – USAID Foreign Assistance for Programs Overseas
98.U04 – USAID Foreign Assistance for Economic Growth
Federal Award Identification Number
98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008;
72060822CA00002; 72066322CA00005
98.U04 – 72026320C00005
Award Year: FY 2022 – 2023
Criteria or specific requirement (including statutory, regulatory or other citation):
2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control:
“The non-Federal entity must:
(a) Establish and maintain effective internal control over the Federal award that provides
reasonable assurance that the non-Federal entity is managing the Federal award in compliance with
Federal statutes, regulations, and the terms and conditions of the Federal award. These internal
controls should be in compliance with guidance in “Standards for Internal Control in the Federal
Government” issued by the Comptroller General of the United States or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).”Family Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 80
Section III – Federal Award Findings and Questioned Costs (continued)
As per 2 CFR Part 170, direct recipients of grants or cooperative agreements are required to report
first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). The subaward information should be reported no later
than the end of the month following the month in which the obligation was made.
Condition:
We noted the following matters during our testing of the Federal Funding Accountability and
Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs
Cause:
A thorough review of the required data elements prior to submission of the reports did not occur
consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or
modifications made during FY 2023 was not performed to identify reports that should have been
submitted.
Effect or Potential Effect:
FHI 360 did not report accurate information or did not submit the required reports for first-tier
subawards of $30,000 or more causing them not to be in compliance with federal reporting
requirements.
Questioned Costs:
NoneFamily Health International
Schedule of Findings and Questioned Costs (continued)
Year Ended September 30, 2023
2311-4384437 82
Section III – Federal Award Findings and Questioned Costs (continued)
Context:
Under the Transparency Act reporting requirements, each FFATA report includes the following
key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4)
Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7)
Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and
8) Date of Report Submission. Testing of the FFATA reports included each of these data elements
as well as verifying for timely submissions. The table presented above lists the specific data
elements where errors were detected as well as any untimely or non-submission of the reports.
Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for
the year ended September 30, 2023.
Identification as a Repeat Finding:
This is a repeat finding from prior year (2022-001).
Recommendation:
We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to
ensure they are both timely and accurately submitted to be in compliance with the federal reporting
requirements.
Views of Responsible Officials:
Management will implement additional actions to enhance and strengthen previous year actions
including global communications and meetings with key management teams, targeted and detailed
refresher training on FFATA requirements and completion of the FSRS template via an e-module,
and additional review of FFATA submissions via a centralized team to identify prospective
transactions and perform a final review of data quality prior to data entry in FSRS. The additional
review will focus on completeness and accuracy of submitted data and timeliness of submissions.
Management notes there were prior year FFATA findings related to timeliness of submissions
which EY concluded upon in May 2023, during the current fiscal period. The corrective action
plan in response to the prior year findings was immediately developed and implemented. This
fiscal year’s control exceptions related to timeliness were prior to the material findings being
concluded upon and the corrective action plan being implemented