Finding Text
Criteria or Specific Requirements: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (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. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions.
Under grant agreements, program 10.761 and 66.446 require both financial and performance reports to be submitted quarterly within 12 days after quarter-end, while ALN program 93.570 requires semiannual financial and performance reports within 30 days after period-end.
Condition: During the review of reporting compliance for the major programs, it was determined that the Organization did not file the FFATA report for program 93.570 within the required 30-day period, and did not submit quarterly financial reports for program 10.761 within the required 12-day deadline after quarter-end.
Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file financial reports in a timely manner.
Effect: Failure to submit the FFATA report by the end of the month following award of a subgrant over $30,000 results in noncompliance with 2 CFR § 170. Additionally, failure to submit quarterly financial reports for program 10.761 within the required deadline constitutes noncompliance with the Federal Financial Reporting requirement under 2 CFR § 200.328.
Questioned Costs: Questioned costs were not identified.
Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore one out of one samples tested for this compliance requirement were not completed. Further, for program 10.761 quarterly financial reports, one out of two samples tested – drawn from a population of 10 – was not submitted within the required 12-day time frame. Noncompliance surrounding reporting was identified for the following awards during the fiscal 2024:
Federal Agency Pass-Through Entity ALN Federal Award Name Award Year
Department of Health and Human Services Direct 93.570 HHS RCD 9/30/2023 – 9/29/2024
United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain
2023 – 2024 9/1/2023 – 9/30/2026
United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal
2023 - 2024 9/1/2023 – 9/30/2026
Repeat Finding: Yes – Repeat of FY 2024 Finding 2023-005.
Recommendations: We recommend that management and relevant staff participate in comprehensive training on federal grant compliance—emphasizing FFATA obligations and financial reporting deadlines—to ensure a clear understanding of requirements. Management should then formalize and document procedures for FFATA reporting, including a calendar-driven workflow with designated preparers and approvers, mandatory sign-off checklists, and automated reminders. Finally, the Organization should implement a centralized reporting-tracking system that monitors all federal award deadlines and captures evidence of timely preparation, review, and submission for both financial and performance reports.