Finding Text
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting
Federal Program: ALN 19.701
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): The
FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime awardees use to
capture and report subaward and executive compensation data regarding their first tier subawards
to meet the FFATA reporting requirements. Prime awardees awarded a Federal grant are required
to file a FFATA sub-award report by the end of the month following the month in which the prime
awardee awards any sub-grant equal to or greater than $30,000. CFR 200.332(a) states that
entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and
includes information related to the Federal award project description, as required to be responsive
to FFATA. CFR 200.341(c) states that the entity must provide the information required under
FFATA to the Federal website established to fulfill the requirements of FFATA, and update or notify
any other relevant government wide systems or entities of any indications of poor performance (or
issues related to suspension or debarment).
Condition: The Global Center has not complied with the aforementioned criteria (we noted no
evidence of a FFATA reporting process).
Cause: The Global Center does not maintain documented policies regarding FFATA reporting and
therefore compliance with Federal regulations cannot be determined.
Effect or Potential Effect: Absent proper policies and procedures, the Global Center is at risk of
entering into sub-awards under Federal awards that were not properly reported and therefore could
result in noncompliance with FFATA requirements.
Questioned Costs: None noted
Context: The issue appears to be systemic.
Identification as a Repeat Finding: Not applicable
Recommendation: We recommend the Global Center establish a FFATA reporting policy to
become compliant with the aforementioned requirements. We further recommend it ensure all staff
are properly trained with respect to the new policy to ensure compliance. In cases where the Global
Center is exempt from reporting or qualifies for a reporting waiver, that conclusion should be
documented in its subgrantee records.