Finding Text
Federal Agency: Department of Defense Federal Assistance Listing Number: 12.431 and 12.800 Program: Basic Scientific Research and Air Force Defense Research Sciences Program Award Number: W911NF-22-2-0050, and FA8650-18-2-5402 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 the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, 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. In accordance with 2 CFR Part 170, Appendix A, under FFATA, SEMI 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 (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: During our testing of FFATA reporting, we selected a sample of three subrecipient awards that were subject to FFATA. All three of the subrecipient awards selected were not submitted in accordance with FFATA submission requirements. Cause: SEMI did not implement policies and procedures to ensure the proper reporting of subrecipient awards in accordance with FFATA. Effect or Potential Effect: SEMI did not report subgrants as required by 2 CFR Part 170. Questioned Costs: None. Context: This is a condition identified based upon our review of SEMI’s compliance with specified requirements. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303. Views of Responsible Officials: Management concurs with this finding. Management will ensure FFATA reports are submitted within the required timeline.