Audit 410471

Finding: 2025-001: Reporting – Federal Funding Accountability and Transparency Act (Noncompliance) Federal Agency and Award Listing Number: U.S. Department of Labor 17.270 – Reentry Employment Opportunities Criteria: Under the Federal Funding Accountability and Transparency Act (FFATA), as amended and codified in 2 CFR Part 170, direct recipients of federal grants and cooperative agreements are required to report first-tier subawards of $30,000 or more to System for Award Management (SAM.gov). The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is required to be reported in SAM.gov no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made. Condition and Context: There were 12 new or amended subawards entered during 2025 that required FFATA reporting. We selected 2 of these agreements for testing and noted that while all the key data elements were accurately submitted, we were unable to validate the timeliness of submission to SAM.gov for both agreements. We noted the following exceptions: Cause: Following the federal system migration, the FFATA reporting platform within SAM.gov no longer displayed or made readily retrievable the submission date associated with individual FFATA reporting. Questioned Costs: None Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Repeat Finding: No Recommendations: We recommend that the Foundation strengthen documentation surrounding submissions made to the SAM.gov system to appropriately capture the date of reporting, including but not limited to screen shots during the submission process and maintain these with the subawardee agreements. This will evidence the submission in SAM.gov, specifically evidencing the submission date. Views of Responsible Officials: Management believes the Foundation acted in good faith and submitted all required FFATA reports in a timely manner. However, limitations within the new SAM.gov FFATA reporting platform prevented the Foundation from independently verifying and documenting the original submission dates. Specifically, use of the bulk upload functionality appears to have overwritten prior submission timestamps with subsequent submission dates, creating the appearance of untimely reporting. Upon identifying the issue, Management contacted its Department of Labor representative and opened a support case with the Federal Service Desk (FSD.gov) to obtain historical submission records. In response to SAM.gov ticket INC-GSAFSD21369739, FSD advised on July 27, 2026, that: “There is no way to currently view a report’s history. This is an enhancement that will be implemented in the future; however, we do not have an estimated release date.” Management believes that access to historical reporting data would substantiate the fact that the reports tested were submitted timely. However, given the system's inability to provide audit evidence and the absence of an alternative means to independently verify prior submission dates, the Foundation has elected to accept the finding. Because the system limitation was neither known nor communicated to users, the Foundation had no opportunity to implement mitigating documentation controls at the time of submission. Had Management been aware of this system limitation, additional procedures, such as retaining screenshots or other contemporaneous evidence of submission, would have been implemented. The Foundation remains committed to full compliance with FFATA requirements and will strengthen its documentation and record-retention procedures to ensure sufficient audit trail for future submissions.