2025–001 Transparency Act Reporting Identification of the federal program: Federal Agency and Program Name: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Healthy Start Initiative Federal Award No: H4903591 Award Year: 2025 Assistance Listing No: 93.926 Criteria or specific requirement (including statutory, regulatory or other citation): Section 200.303 of the Uniform Guidance states the following regarding internal control: “The recipient and subrecipient must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. The internal controls should align with the 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).” Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, “unless the recipient is exempt as provided in paragraph d. of this award term, the recipient must report each subaward that equals or exceeds $30,000 in Federal funds for a subaward to an entity or Federal Agency. The recipient must also report a subaward if a modification increases the Federal funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of the subaward”. The recipient must report each subaward no later than the end of the month following the month in which the subward was made. Condition: During our audit, we noted four instances where the required Federal Funding Accountability and Transparency Act (FFATA) reports were not submitted in SAM.gov timely in FY 2025. In addition, we noted for all six FFATA reports that were submitted in SAM.gov, there was no evidence of review and approval of the reports prior to submission. Cause: Corewell implemented corrective actions effective September 1, 2025 based on prior year audit finding. Due to the timing of the implementation of the corrective action plan, the FFATA reports that were due prior to September 1, 2025 were not submitted timely and documentation supporting the review of the FFATA reports was not maintained causing a repeat finding in the current year. Effect or potential effect: Corewell did not timely submit the necessary FFATA reports under the Healthy Start Initiative (HSI) project for each first-tier subaward agreement or modifications in SAM.gov and consequently was not in compliance with the requirements under the Transparency Act. Additionally, lack of review could potentially result in incorrect information included in the reports. Questioned costs: $0 Context: Under the HSI program, there were five subrecipients that had a total of six subawards (one new agreement and five amendments) in FY 2025. Total subrecipient’s costs are $750,822 in FY 2025. The total federal expenditures for the HSI program for FY 2025 were $1,052,118. Identification as a repeat finding, if applicable: Repeat finding – 2024-001 Recommendation: We recommend management ensure that the implemented corrective action plans are followed to ensure the required FFATA reports are submitted timely and documentation retained to support the internal control review performed prior to submission of the reports. Views of responsible officials: Management has implemented a comprehensive corrective action plan to address the FFATA reporting deficiencies identified in the prior audit. Effective September 1, 2025, Corewell Health established a formal written FFATA reporting procedure that includes detailed requirements for identifying and reporting amended subawards throughout the award lifecycle. The procedure also requires documented supervisory review and approval of all FFATA submissions prior to filing to ensure completeness, accuracy, and compliance with federal reporting requirements. The procedure has been formally communicated to and implemented by the Office of Sponsored Programs and Research Finance teams. Ongoing training, monitoring, and periodic reviews of compliance with the procedure have been incorporated into operational processes to reinforce adherence to reporting requirements and to prevent recurrence. Although these corrective actions were implemented effective September 1, 2025, certain FFATA reporting deadlines applicable to the current audit period occurred before the implementation date. As a result, reports due prior to September 1, 2025 were not submitted within the required timeframe and did not include documented evidence of review before submission. Consequently, the finding was reported as a repeat finding in the current audit period. Management believes the corrective actions now in place adequately address the underlying control deficiencies and will support timely and compliant FFATA reporting going forward.