Finding 1146492 (2023-006)

Finding 2023-006 – Federal Funding Accountability and Transparency Act Reporting (Significant Deficiency) Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: N/A – Direct Award Program Name: Head Start Cluster Assistance Listing Number: 93.600 Award Numbers: 05CH010935-04-01, 05CH010935-05-00, 05HE00049701C5 (COVID-19), and 05HE00049701C6 (COVID-19) Category of Finding: Reporting Criteria – Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), modified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System (FSRS) no later than the end of the month following the month in which the subaward obligation was made. Condition and Context – During our testing of the reporting compliance requirement related to the Head Start Cluster, it was determined that the FFATA reporting to FSRS was not completed timely. Effect – Failure to submit the required FFATA reports by the end of the month following an award given to a subrecipient results in noncompliance with 2 CFR Part 170. Noncompliance with required reporting requirements could jeopardize current/future funding. Cause – Due to significant turnover in key fiscal reporting personnel and lack of communication regarding 2 CFR reporting requirements, the filing deadlines for the FFATA reporting were missed. The Organization subsequently identified the issue approximately nine months after the required reporting deadline and took steps to complete the proper reports. Recommendation – The Organization should evaluate each award with subrecipient payments for applicability of FFATA reporting and develop processes and internal controls to ensure proper submission of reports in accordance with the requirements of the Federal Funding Accountability and Transparency Act. Cross-training in the fiscal area should be conducted so that the reporting requirements are known by several fiscal personnel so that, in the event of turnover, reporting requirements would not be missed. Questioned Costs – None Repeat Finding – No View of Responsible Officials – Management agrees with this finding. Please see Management’s Corrective Action Plan.