Finding 1002278 (2022-001)

Federal Award Identification Number and Award Year:SECAGD18CA0067 2018 ? 2021SECAGD20CA0075 2020 ? 2023SECAGD20CA0075 2020 ? 202372049719C00001 2019 ? 202472049719C00001 2019 ? 202472049719C00001 2019 ? 2024Section III ? Federal Award Findings and Questioned Costs (continued)Criteria: As per 2 CFR 200.170, direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The subaward information should be reported no later than the end of the month following the month in which the obligation was made.Condition: During our testing of the FFATA reporting compliance, we tested a sample of ten (10) FFATA reports that were submitted to FSRS and found that six (6) reports from our sample were not submitted within the required time frame.Cause: The information needed for FFATA reporting is provided by the implementing partner and Country Office to FHI 360?s Contract Management Service group for submission. In these six instances, the information was not processed, and the reports were not prepared, on a timely basis.Effect or Potential Effect: The delay in submission of the reports resulted in FHI 360 not reporting the required information in FSRS within the required time frame; thereby resulting in noncompliance with the reporting requirements. Although the six reports were not submitted within the required time frame, we noted that upon their eventual submission, the information submitted was complete and accurate and met all other compliance requirements.Questioned costs: None.Context: Of the ten (10) FFATA reports tested, we noted delays in submission of six (6) reports.Identification as a repeat finding, if applicable: Not applicableRecommendation: We recommend FHI 360 continue to reinforce the importance of timely submission of required documents to all business units involved in the FFATA reporting process and continue to monitor the appropriate compliance with timely reporting.Views of responsible officials:Management has stressed the criticality of prompt submission through comprehensive globalcommunications from the corporate headquarters. This directive will emphasize coordinating withvarious departmental heads to reinforce the requirement across different levels of the organization.Management is implementing a worldwide procurement system to structure the current reportingframework.It?s important to note that a significant factor in one of the reported delays was the U.S.government?s shift from DUNS to UEI as the unique identifier. This alteration necessitatedobtaining a UEI, which wasn?t required at the transaction?s point of execution, leading to a delayin reporting. The removal of the DUNS field as a validating data point from FSRS occurred beforeour transaction reporting deadline.This changeover also extended the reporting delay of a transaction, initially one month late, tothree months. Even though the transaction was duly initiated under a DUNS, the subsequent needto acquire a UEI for entry into the FSRS resulted in an extended submission delay.