Finding 1054722 (2023-001)

FFATA Reporting Information on Federal Program - Program Name: Building Resilient Economies in Coal Communities (BRECC) Community of Practice Initiative Assistance Listing Number: 11.307 Agency: Department of Commerce - Economic Development Administration Grant Award Number: ED22HDQ3070080 Year: 2023 Criteria or Specific Requirement – In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the "Transparency Act" that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of S30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The prime awardee is required to file a Transparency Act sub-award report 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. Condition - The Foundation did not submit the required subrecipient information within the prescribed timeline. This information should include the subrecipient's name, the amount of the subaward, the subrecipient's DUNS number, the primary location of the subrecipient, and other relevant data as required by FFATA. Cause – Management's internal processes and procedures related to the identification of reporting requirements did not allow the Foundation to identify, on a timely basis, the requirement to complete the FFATA reporting. Effect or Potential Effect - Failure to report subrecipient information in a timely manner can result in a lack of transparency and accountability, which is contrary to the intent of FFATA. It may also lead to potential noncompliance with federal regulations and could affect future funding. Questioned Costs - Not determinable. Context – The population consists of two subrecipients for the major program. The foundation did not submit the required FFATA reporting for these two subrecipients. Recommendation – The Foundation should establish and implement procedures to ensure that all FFATA reporting requirements are met in a timely manner. This includes training for relevant staff on FFATA compliance, regular reviews of reporting deadlines, and the establishment of internal controls to ensure complete and accurate reporting of subaward information. Views of Responsible Officials – The Foundation agrees with the finding. Upon becoming aware of these obligations, efforts were immediately made to comply. The Foundation reached out to the grantor for guidance and took proactive steps, and the subrecipient information was subsequently added to the system to ensure compliance.