Audit 396665

2025-001 - Reporting (Special Reporting under FFATA) Significant Deficiency in Internal Controls Over Compliance and Instance of Noncompliance Assistance Listing Number: 93.591 Federal Agency/Pass-through Entity - Program Name: Department of Health and Human Services - COVID-19 Family Violence Prevention Services/State Domestic Violence Coalitions Award Number(s):2201WYSTC6 & 2101WYSDC6 Award Year(s): 2020-2025 Criteria or specific requirement: The Uniform Guidance in 2 CFR Section 200.303, Internal Controls, requires that non-Federal entities receiving Federal awards (i.e. auditee management) establish and maintain internal control designed to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR Part 170 require prime recipients of federal awards to report certain information for subawards. Specifically, 2 CFR 170.220(a) requires prime recipients to report information on subawards equal to or greater than $30,000 in the Subaward Reporting System available through SAM.gov (formerly the Federal Subaward Reporting System - FSRS). The information must generally be reported by the end of the month following the month in which the subaward obligation was made. Condition: During our testing of FFATA subaward reporting requirements, we noted that the Coalition issued one subaward during the audit period to the Eastern Shoshone Business Council totaling $115,993. The subaward exceeded the $30,000 FFATA reporting threshold and therefore required reporting in the Subaward Reporting System within SAM.gov. However, the Coalition did not report the subaward in SAM.gov as required. Questioned costs: None. The issue relates to reporting compliance, and no questioned costs were identified. Context: The population consisted of one subaward, which was tested in its entirety. Cause: The Coalition did not have formal procedures or controls in place to identify subawards subject to FFATA reporting requirements and ensure they were reported in the Subaward Reporting System within SAM.gov. Management indicated they were unaware that the agreement met the definition of a reportable subaward under FFATA. As a result, the subaward was not evaluated for reporting requirements at the time the agreement was executed. Effect or potential effect: Failure to report required subaward information results in noncompliance with FFATA transparency reporting requirements and reduces the availability of public information regarding the use of federal funds. Additionally, the absence of established controls increases the risk that future reportable subawards may not be properly reported. Repeat finding: No Recommendation: We recommend the Coalition strengthen internal controls over federal award reporting by: • Implementing procedures to identify subawards subject to FFATA reporting requirements when agreements are executed. • Assigning responsibility for timely submission of required subaward reports through the Subaward Reporting System within SAM.gov. • Providing training to grant management and finance personnel on FFATA reporting requirements. • Implementing a monitoring or review control to ensure required reports are submitted timely. Views of responsible officials: Management agrees with the finding and will implement procedures to ensure compliance with FFATA reporting requirements, including timely filing of all subgrant awards exceeding $30,000 with SAM.gov within one week of the finalized award agreement.