Audit 393727

2025-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement (Significant Deficiency) Information on the Federal Program: United States Agency for International Development Assistance Listing Number: 98.001 Assistance Listing Name: USAID Foreign Assistance for Programs Overseas Direct Award Numbers Award Period 720BHA23GR00031 February 1, 2023 through January 31, 2026 72068324GR00002 September 7, 2024 through December 31, 2024 Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must 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. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Subaward Reporting in SAM.gov. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: We performed testing over CRS’s compliance with specific FFATA reporting requirements. Of the eight sub-award reports selected for testing, two of the reports with sub-award amounts totaling $313,190 were not submitted within the required timeframe. Specifically, the two FFATA reports were filed between 64 and 66 days later than the required filing date. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of CRS’s compliance with specified requirements. The samples were selected using a non-statistical sampling method. Cause: Although CRS has existing internal control policies and procedures ensuring appropriate filing of sub-award information in SAM.gov, the country offices failed to file the FFATA reports on time. Effect: Failure to report subrecipient information in a timely manner can result in lack of transparency and accountability, which is contrary to the intent of FFATA. Such non-compliance also increases the risk of loss of future awards if compliance with award terms is not met. Repeat Finding: No. Recommendation: We recommend that management ensure that all FFATA reports are filed in a timely manner. In addition, management should strengthen the existing internal controls and conduct refresher training to CRS country office personnel emphasizing timely submission of FFATA reports. Views of Responsible Officials: CRS management agrees with the finding and recommendations and will enhance the processes around timely submission of FFATA reports.