Reference Number: 2023-001
Prior Year Finding: No
Federal Agency: U.S. Department of Labor
Department Name: Mississippi Department of Employment Security
Federal Program: WIOA Cluster
Assistance Listing Number: 17.258, 17.259, 17.278
Award Number and Year: 7/1/22 – 6/30/23
Compliance
Requirement:
Re...
Reference Number: 2023-001
Prior Year Finding: No
Federal Agency: U.S. Department of Labor
Department Name: Mississippi Department of Employment Security
Federal Program: WIOA Cluster
Assistance Listing Number: 17.258, 17.259, 17.278
Award Number and Year: 7/1/22 – 6/30/23
Compliance
Requirement:
Reporting – Federal Funding Accountability and
Transparency Act (FFATA)
Type of Finding: Material Weakness in Internal Control Over
Compliance, Material Noncompliance
Criteria or specific requirement:
Compliance: Per the Federal Funding Accountability and Transparency Act (FFATA),
prime (direct) recipients of grants or cooperative agreements are required to report firsttier
subawards of $30,000 or more to the Federal Funding Accountability and Transparency
Act Subaward Reporting System (FSRS). Reports must be filed in FSRS 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. If the initial award is below $30,000 but subsequent grant
modifications result in a total award equal to or over $30,000, the award will be subject to
the reporting requirements as of the date the award exceeds $30,000. If the initial award
equals or exceeds $30,000 but funding is subsequently de-obligated such that the total award amount falls below $30,000, the award continues to be subject to FFATA reporting
requirements.
Control: Per 2 CFR section 200.303(a), 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. These internal controls
should comply with 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).
Condition:
The Mississippi Department of Employment Security (MDES) did not report subaward
information to FSRS within thirty days after issuing the subaward or subaward amendment.
Context:
Nine subawards were selected for testing which included five original subawards and four
amendments. We noted the following exceptions:
1 of 9 subawards should have been reported by 11/30/2022 but was not reported
before the end of FY 2023. The subaward was subsequently reported in February
2024.
3 of 9 subawards should have been reported by 5/31/2023 but were not reported
before the end of FY 2023. The subawards were subsequently reported in February
2024.
4 of 9 subawards should have been reported no later than 2/28/2023 but they were
reported on 3/29/2023, or 29 days late. Cause:
MDES’s procedures and controls were not sufficient to ensure that subawards were
reported to FSRS no later than the end of the month following the month of issuance.
Effect:
Subawards were not reported to FSRS in accordance with FFATA requirements. Questioned costs:
None noted.
Recommendation:
We recommend MDES establish procedures and internal controls to ensure that all required
subawards are reported timely to FSRS no later than the end of the month following the
month of issuance of each subaward.
Views of responsible officials: MDES Response
MDES concurs that the program year 2022 subawards were not entered into the Federal
Funding Accountability and Transparency Act Subaward Reporting System (FSRS) within
thirty days of subaward issuance. The practice of MDES has been to enter all subawards
into the FSRS at one time and later perform a look back to determine the adjustments
needed to bring the reported balances up or down based on subaward amendments made
during the year. Specifically, for program year 2022 subawards, the initial entry into FSRS
was on 3/29/2023 with the post award adjustment entry made February 23, 2024.
Corrective Action Plan:
a. MDES Plan: MDES will strengthen controls around FSRS reporting to ensure
subawards are reported to FSRS within thirty days of issuance. MDES will also
monitor subaward amendments and ensure they are reported within thirty days of
issuance. Entries into the FSRS will be reviewed by the supervisor to ensure
compliance. This process is effective immediately.
b. Contact Person Responsible: Comptroller.
c. Anticipated Corrective Action Plan Completion Date: July 15, 2024.