Finding Text
Finding 2024-001 - Reporting: Federal Funding Accountability and Transparency Act ("FFATA") - Significant Deficiency Name of Federal Agency: U.S. Department of Health and Human Services Federal Program Names: Health Center Program Cluster - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and COVID-19 - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care, Grants for New and Expanded Services Under the Health Center Program, and COVID-19 - Grants for New and Expanded Services Under the Health Center Program; Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease Assistance Listing Numbers: 93.224, 93.527, and 93.918 Federal Award Identification Numbers and Years: Health Center Program Cluster: H8FCS40832 - 2021, H80CS00626 - 2022, H8CS00626 - 2023, H8LCS51759 - 2023, H8KCS49691 - 2023, and H8KCS49691 - 2024; Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease: H76HA00521 - 2023, and H76HA00521 - 2024 Criteria 1. In accordance with 2 CFR Section 200.303, Internal Controls, the nonFederal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonFederal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2. Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, prime 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). The prime recipient is required to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition Health Center Program Cluster: 1. During our audit, we noted the FFATA subawards were not submitted timely to the FSRS. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 2 0 2 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $4,153,728 $0 $4,153,728 $0 $0 Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease: 2. During our audit, we noted the evidence of review and approval was performed after the FFATA subaward was submitted to the FSRS. 3. During our audit, we noted the FFATA subawards were not submitted timely to the FSRS. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 1 0 1 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $191,710 $0 $191,710 $0 $0 Cause Health Center Program Cluster: 1. As a result of personnel changes within the finance department, the FFATA reporting was not done timely. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease: 2. There is no formal policy in place requiring the CFO (or designee) to review and approve the FFATA reports before submission to the FSRS. 3. As a result of personnel changes within the finance department, the FFATA reporting was not done timely. Effect or Potential Effect 1. The condition could result in key data elements inaccurately reported and/or not supported by the source documentation. 2. The FFATA subawards were not submitted timely to the FSRS. Questioned Costs None. Context Health Center Program Cluster: Two exceptions from a statistically valid sample of two. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease: One exception from a statistically valid sample of one. Identification as Repeat Finding Health Center Program Cluster: 1. Yes (see prior year finding number 2023-002) Recommendation Health Center Program Cluster: 1. We recommend that management create an e-mail reminder or other alert mechanism and implement controls to ensure compliance with the reporting requirements under FFATA. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease: 2. We recommend that all FFATA reports be reviewed and approved by the CFO or designee before submission to FSRS and evidence of approval be maintained. 3. We recommend that management create an e-mail reminder or other alert mechanism and implement controls to ensure compliance with the reporting requirements under FFATA. Views of Responsible Officials Health Center Program Cluster: 1. BCHN has created a policy regarding the FFATA reporting process. In this process the Electronic Handbook (EHB) is reviewed weekly to ensure that if new awarded funding is released, BCHN is alerted to the need to complete the FFATA report. BCHN has created a spreadsheet to track all the awarded funding and due dates for FFATA reports. Every month, at the board meeting, the spreadsheet is presented to the board with any new awarded funding and when the FFATA report is completed. Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease: 2. BCHN has begun a process where the FFATA report is put together by the Finance Manager and reviewed and signed off by the CFO before submitting the report. 3. BCHN has created a policy regarding the FFATA reporting process. In this process the Electronic Handbook (EHB) is reviewed weekly to ensure that if new awarded funding is released, BCHN is alerted to the need to complete the FFATA report. BCHN has created a spreadsheet to track all the awarded funding and due dates for FFATA reports. Every month, at the board meeting, the spreadsheet is presented to the board with any new awarded funding and when the FFATA report is completed.