Finding 1154168 (2024-003)

Material Weakness Repeat Finding
Requirement
CL
Questioned Costs
-
Year
2024
Accepted
2025-09-23

AI Summary

  • Core Issue: The Organization failed to meet FFATA reporting requirements and had outdated cash management procedures.
  • Impacted Requirements: Compliance with the Federal Funding Accountability and Transparency Act and updated cash management policies as per 2 CFR Part 200.305.
  • Recommended Follow-up: Implement new processes for reporting and update cash management policies to align with current staffing and procedures.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name - 11.611, United States Department of Commerce, National Institute of Standards and Technology Federal Award Identification Number and Year - 70NANB20H067 Pass through Entity - Not applicable - Direct funded Finding Type - Significant deficiency and material noncompliance with laws and regulations Repeat Finding - Yes, 2023-002/2023-003 Criteria - The Federal Funding Accountability and Transparency Act (FFATA), as amended by 6202 of Public Law 110-252, requires a prime grant awardee to report its subgrants using the FFATA Subaward Reporting System (FSRS) tool. The prime recipient will have until the end of the month plus one additional month after an award or subaward is obligated to fulfill the reporting requirement. In addition, written procedures to implement cash management requirements should be in place and updated in accordance with 2 CFR Part 200.305. Condition The Organization did not have the appropriate controls in place over FFATA reporting and did not file the required reports. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. This finding is repeated from the December 31, 2023 audit. Questioned Costs - Not applicable Identification of How Questioned Costs Were Computed - Not applicable Context - The following table summarizes the transactions examined and the noncompliance identified for FFATA: Additionally, the cash management policy was not updated when there was restructuring in the finance department during the prior fiscal year. Cause and Effect - A process was not in place for the Organization to determine the required reports to be submitted under the grant. The outdated cash management policy was not reflective of the actual process. Recommendation - The Organization must implement processes and controls to identify and comply with funding agency reporting requirements. Additionally, the cash management policy should be updated to reflect the new process. Views of Responsible Officials and Corrective Action Plan - Reporting was completed in SAM.gov in May 2025 for subrecipient subaward amount based on the award period running from calendar periods of July to June.

Corrective Action Plan

Condition: The Organization did not have the appropriate controls in place over FFATA reporting and did not file the required reports. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Planned Corrective Action: Reporting was completed in SAM.gov in May 2025 for subrecipient subaward amount based on the award period running from calendar periods of July to June. Written internal MMTC procedures regarding cash management will be updated and will include the current staff. Contact person responsible for corrective action: Alan Kowalewski Anticipated Completion Date: 10/31/2025

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management Reporting Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.611 Manufacturing Extension Partnership $252,788
11.307 Economic Adjustment Assistance $88,710
12.600 Community Investment $2,434
17.278 Wioa Dislocated Worker Formula Grants $2,000