Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Taylor McCabe, Director of Grants Management, and Finance Lead, Tia Newcom
Anticipated Completion Date: Expected completion by December 31, 2024Corrective Action Plan: The audit identified that FFATA (Federal F...
Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Taylor McCabe, Director of Grants Management, and Finance Lead, Tia Newcom
Anticipated Completion Date: Expected completion by December 31, 2024Corrective Action Plan: The audit identified that FFATA (Federal Funding Accountability and Transparency Act) subaward reports were not submitted properly or on time for first-tier subawards of $30,000 or more. The deficiency was attributed to a lack of awareness of this requirement and the absence of specific internal controls to ensure timely reporting to the Federal Subaward Reporting System (FSRS). To address this finding and establish compliance with 2 CFR Part 170, BioSTL has implemented additional measures and expanded policies and procedures to ensure timely reporting to the FSRS. To ensure the highest compliance, BioSTL has incorporated the standard federal FFATA form as an exhibit within the subawardee contracts, ensuring timely collection
of necessary data. This incorporation not only enables the direct gathering of general information within the contract but also includes the requirement for subawardees to complete and sign the standard FFATA form. This approach is paired with additional training and education for both BioSTL’s Grant Management personnel, Program Directors, and the leadership team within subawardee organizations, ensuring that all
parties are fully aware of the initial and any ongoing reporting requirements. Through the formalized contractual process, BioSTL has implemented enhanced internal controls by requiring supervisory review and approval at multiple levels. Submitted FFATA documentation will undergo review by the Program Director managing the grant, the Director of Grants Management, and the Vice President of Development, ensuring thorough oversight and compliance at each step. To support this process, BioSTL has implemented an Airtable-based compliance reminder system to automate notifications related to FFATA form submissions.
Automated reminders will be sent to both pass-through partners and relevant program staff, reminding them to complete the annual FFATA form submission. Notifications will be issued on September 1st as a 30-day advance notice and again on September 15th, with a final submission deadline to BioSTL set for September 30th of each year. These reminders ensure proactive follow-up and help maintain annual compliance. BioSTL will also ensure that both Program Directors and the Grants Department thoroughly review all submitted FFATA documents, reinforcing accuracy and adherence to reporting timelines.