Finding Text
Internal Control over Compliance and Compliance with the Reporting Compliance Requirement
Identification of the Federal Program:
United States Agency for International Development (USAID)
Assistance Listing Number: 98.001
Assistance Listing Name: USAID Foreign Assistance for Programs Overseas
Award Number: 720BHA24GR00016
Award Period: December 15, 2023 through December 31, 2026
Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, 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.
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 $30,000 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 granter than or equal to $30,000.
Condition: During BDO’s testing of the FFATA reporting, we tested the only subrecipient in the major program. ChildFund entered into the subaward agreement with the entity in January 2024, however ChildFund did not report activity in the FSRS system until October 2024.
Cause: There was turnover at ChildFund in the personnel who is responsible for the Transparency Act reports and it was not initially identified that someone had not assumed that responsibility until our audit procedures identified the missing report.
Effect: Failure to properly track all Transparency Act reporting requirements impacts the Federal agency from obtaining performance information required to assess award performance on a macro level.
Questioned Costs: There are no questioned costs as the items outlined above are all matters relate to late submission of required reports.
Context: This is a condition identified during BDO’s testing of Transparency Act reports. We tested the only required FFATA report submission for the year ended June 30, 2024.
Repeat Finding: This finding is not a repeat finding.
Recommendation: To facilitate accurate and timely reporting and compliance with the terms and conditions of federal awards, BDO recommends management implement a process by which approvals, submission considerations and supporting documentation for programmatic reports and Transparency Act reports is maintained in a centralized location.
Views of Responsible Officials: Management agrees with the finding. Please see Appendix B for Management’s Corrective Action Plan.