Finding 1135509 (2023-002)

Federal Program: Assistance Listing #93.912 - Rural Communities Opioid Response Program Criteria: In accordance with the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, 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). Condition: Illuminate Colorado was a direct recipient of Rural Communities Opioid Response Program funds. Illuminate Colorado made first-tier subawards of more than $30,000 to two subrecipients to carry out part of the Rural Communities Opioid Response Program These firsttier subawards were not reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs: None. Cause and Effect: Primary Project Director and Primary Program Manager assigned to this grant were both out on parental leave during Q4 of 2023 when this Federal Grant was being initiated internally. Back up personnel assigned to provide coverage during the leave and review the terms and conditions of the award did not identify the Federal Funding Accountability and Transparency Act Persons reporting requirements. Recommendation: We recommend Illuminate Colorado communicate Federal Funding Accountability and Transparency Act reporting requirements to program management. This can be communicated by flowcharting/decision tree. Management’s Response: Illuminate Colorado has developed a new process for initiating federal grants that includes a review of Terms and Conditions by multiple individuals to ensure all required Terms and Conditions are identified and implemented. This process includes documentation of compliance with requirements for subrecipients.