Finding Text
Finding 2023-001 Significant Deficiency: Reporting - Compliance and Control Finding
ALN 11.307 – Economic Development Cluster
Federal Agency: U.S. Department of Commerce
Pass-Through Entity: N/A
Criteria Or Specific Requirement: 2 CFR Part 170 requires direct recipients of grants to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) no later than the last day of the month following the month in which the agreement was made. Additionally, proper controls must be in place surrounding review and approval
of the report prior to submission to FSRS.
Condition: Audit procedures revealed that the FFATA reports were not properly or timely submitted.
Cause: Management was not aware FFATA reports were an applicable requirement of the federal program. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements.
Effect: Instances of noncompliance were not detected by management.
Context: Reports for subrecipients who were awarded over $30,000 in federal funding were not compiled, reviewed or submitted by last day of the month following the month in which the agreement was made.
Questioned Costs: None.
Identification As A Repeat Finding: Not applicable.
Recommendation: We recommend that management compile and submit FFATA report timely for all subrecipient agreements for greater than $30,000 in federal funding with proper review and approval prior to submission. Views Of Responsible Officials: 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.