Finding Text
Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-Federal entities
receiving Federal awards (i.e., auditee management) establish and maintain internal control
designed to reasonably ensure compliance with Federal statues, regulations, and the terms and
conditions of the Federal award.
In accordance with 2 CFR Part 170, Appendix A, under the Federal Funding Accountability and
Transparency Act (FFATA), the department is required to collect and report information on each
subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting
System. The non-Federal entity or Federal agency must report each obligating action described in
paragraph a.1. of this award term to http://www.fsrs.gov.
In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is
responsible for complying with all requirements of the Federal award. For all Federal awards, this
includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance
Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting
Subaward and Executive Compensation Information.
Condition: During our subrecipient testing for the major program, we were unable to verify the
submission dates of the FFATA Report via the Federal Funding Accountability and Transparency Act
Subaward Reporting System (FSRS) website. The Organization was unable to provide evidence of
submission, lacking retained documentation that evidenced the actual submission dates of the
FFATA reports.
Cause: It was determined that the absence of supporting documentation was a result of the FSRS
system migration to SAM.gov. The Organization neglected to keep documentation to support
submission.
Effect: The inability to verify the submission dates of the FFATA reports due to missing
documentation may lead to compliance issues with federal reporting requirements.
Questioned Costs: None.
Context: This is a condition identified per review of the Organization’s compliance with the
reporting provisions of the Uniform Guidance.
Repeat Finding: This finding is not a repeat finding from the prior year.
Recommendation: BDO recommends that the Organization establish a comprehensive system for
retaining submission records, including timestamps and confirmation receipts, to ensure all future
FFATA report submissions are verifiable.
Views of Responsible Officials: Management agrees with the finding and recommendations set forth
within and has developed a corrective action plan to address the instances of noncompliance
identified and lapses in prescribed internal controls.