FAC Explorer

Audit 322582

FY End
2023-12-31
Total Expended
$2.59M
Findings
16
Programs
2
Organization: Global Center on Cooperative Security (DC)
Year: 2023 Accepted: 2024-09-30
Auditor: Gelman Rosenberg & Freedman

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
499754 2023-002 Significant Deficiency - L
499755 2023-003 Significant Deficiency - H
499756 2023-002 Significant Deficiency - L
499757 2023-003 Significant Deficiency - H
499758 2023-002 Significant Deficiency - L
499759 2023-003 Significant Deficiency - H
499760 2023-002 Significant Deficiency - L
499761 2023-003 Significant Deficiency - H
1076196 2023-002 Significant Deficiency - L
1076197 2023-003 Significant Deficiency - H
1076198 2023-002 Significant Deficiency - L
1076199 2023-003 Significant Deficiency - H
1076200 2023-002 Significant Deficiency - L
1076201 2023-003 Significant Deficiency - H
1076202 2023-002 Significant Deficiency - L
1076203 2023-003 Significant Deficiency - H

Programs

ALN Program Spent Major Findings
19.701 Global Counterterrorism Programs $1.03M Yes 2
19.124 East Asia and Pacific Grants Program $289,755 - 0

Contacts

Name Title Type
J376ZE9FVFS7 Daniel Grimshaw Auditee
7033146051 Max Manley Auditor
No contacts on file

Notes to SEFA

Title: Note 1. Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Global Center has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (the Schedule) includes the Federal award activity of the Global Center under programs of the Federal government for the year ended December 31, 2023. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Schedule presents only a selected portion of the operations of the Global Center; accordingly, it is not intended to and does not present the financial position, changes in net assets or cash flows of the Global Center.
Title: Note 2. Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Global Center has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Global Center has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance.
Title: Note 3. Reconciliation of Grant Revenue Accounting Policies: Expenditures reported on the Schedule are reported on the accrual basis of accounting. De Minimis Rate Used: N Rate Explanation: Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Global Center has elected not to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance. Total grant and contract revenue is made up of the following as of December 31, 2023: U.S Government Grants $ 2,590,119 Non-U.S. Governmental Grants and Contracts 2,869,209 TOTAL GRANT AND CONTRACT REVENUE $ 5,459,328

Finding Details

Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.
Finding 2023-002
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to capture and report subaward and executive compensation data regarding their first tier subawards to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes information related to the Federal award project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must provide the information required under FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify any other relevant government wide systems or entities of any indications of poor performance (or issues related to suspension or debarment). Condition: The Global Center has not complied with the aforementioned criteria (we noted no evidence of a FFATA reporting process). Cause: The Global Center does not maintain documented policies regarding FFATA reporting and therefore compliance with Federal regulations cannot be determined. Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of entering into sub-awards under Federal awards that were not properly reported and therefore could result in noncompliance with FFATA requirements. Questioned Costs: None noted Context: The issue appears to be systemic. Identification as a Repeat Finding: Not applicable Recommendation: We recommend the Global Center establish a FFATA reporting policy to become compliant with the aforementioned requirements. We further recommend it ensure all staff are properly trained with respect to the new policy to ensure compliance. In cases where the Global Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee records.
Finding 2023-003
Finding 2023-003: Period of Performance Federal Program: ALN 19.701 Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): According to 2 CFR Part 200, Uniform Guidance, §200.309 - Period of Performance, Federal awards must comply with the specified period of performance outlined in the award documentation. The period of performance defines the timeframe during which the recipient may incur costs and complete the project or program objectives. Condition: During the audit period, the Global Center had two active awards serving nearly identical purposes. The first award concluded in September 2023, at which point the follow-on award commenced. In July 2023, the Global Center incurred an expense, believing it could be charged to the follow-on award. The Global Center requested authorization from the donor to charge the cost to the award, even though it was incurred prior to the commencement of the period of performance. While awaiting confirmation from the donor, the Global Center went ahead and billed the expense to the award. The donor, however, took nearly a year to respond and ultimately ruled the cost unallowable. The Global Center subsequently reclassified the cost out of the award. Cause: Administrative delays and miscommunication with the donor. Effect or Potential Effect: As a result of initially recording an expense incurred prior to the commencement of the period of performance before it had specific authorization to do so, the Global Center inadvertently drew down funds for this unapproved cost. Questioned Costs: None noted Context: By recording the expense before receiving donor confirmation, the Global Center risks incurring and claiming costs outside of the allowable period for reimbursement. Identification as a Repeat Finding: Not applicable Recommendation: The Global Center should refrain from recording any expenses outside the period of performance until written approval is received from the donor, ensuring compliance with award guidelines.