Audit 383575

Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Head Start Cluster Assistance Listing Number: 93.600 Federal Award Identification Number and Year: 01CH011362 Name of Pass-through Entity (if applicable): N/A Criteria Under the requirements of the Federal Funding Accountability and Transparency Act ("FFATA") that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to identify awards subject to FFATA, collect and report information on each first tier subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System. Condition During our testing of FFATA reporting requirements, we noted the Organization did not perform the mandatory FFATA reporting requirements. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 4 4 0 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $1,638,712 $1,638,712 $0 $0 $0 Cause The Organization did not have adequate policies, procedures, and controls in place to ensure compliance with the requirements regarding FFATA reporting. Effect or Potential Effect Failure to comply with the reporting requirements of the Uniform Guidance could result in noncompliance with laws and regulations. Questioned Costs None. Context See the context of the finding detailed in the condition section above. Identification as a Repeat Finding This finding is not a repeat finding. Recommendation We recommend that the Organization establish policies, procedures, and controls to ensure that the required information is reported in the FFATA Subaward Reporting System on a timely basis. Views of Responsible Officials Management takes this matter seriously and is committed to strengthening our internal processes in order to ensure accurate reporting of Federal Expenditures. Finance personnel who are responsible for management of Federal grants have undergone targeted training around Uniform Guidance requirements with respect to grants management and sub-recipient compliance. UWGNH also maintains an active registration in the System for Award Management (SAM). Finance personnel have recently been trained on the procedure for submitting FFATA reporting in SAM.gov and are clear on the requirements. They are aware of the requirement to report subawards of more than $30,000 from federal funds. This task has been added to the internal accounting close checklist and will be completed during any period where sub-awards have been executed. The CFO will oversee the implementation of these corrective actions and monitor ongoing compliance.