Finding 1156379 (2024-004)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
$1
Year
2024
Accepted
2025-09-29
Audit: 368692
Organization: 9/11 Day (CA)
Auditor: Eide Bailly

AI Summary

  • Core Issue: There is a material weakness in internal controls over compliance, specifically regarding FFATA reporting for subawards exceeding $30,000.
  • Impacted Requirements: Compliance with 2 CFR 200.303(a), 200.328, 200.329, and FFATA reporting requirements was not met.
  • Recommended Follow-Up: Management should review and improve procedures to ensure compliance with federal reporting requirements.

Finding Text

2024-004 Corporation for National and Community Service Federal Financial Assistance Listing #94.012, 22BIICA001 10/1/2022 – 9/30/2025, 23BIACA001 10/1/2023 – 9/30/2026, 23BIFNY001 10/1/2023 – 9/30/2026 Americorps September 11th National Day of Service and Remembrance Grants Reporting Material Weakness in Internal Controls over Compliance and Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. 2 CFR 200.328 and 2 CFR 200.329 require the auditee to collect financial information and monitor its activities under federal awards to assure compliance with applicable federal requirements and performance expectations are being achieved and report these items in accordance with the program requirements. 2 CFR Part 170 establishes requirements for recipients’ reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA). Condition: Reporting of information on subawards as required by the Federal Funding Accountability and Transparency Act of 2006 (FFATA) was not completed for each of the four subrecipients in which pass through funds exceeded $30,000. Cause: There was a misunderstanding with management over reporting requirements surrounding amounts passed through to subrecipients. Effect: Not having a clear understanding of FFATA reporting requirements lead to required information not being reported. Questioned Costs: None reported. Context/Sampling: There was a total of six federal financial reports, of which 2 were selected for testing. There were a total of four FFATA reports, of which 2 were selected for testing. Repeat Finding from Prior Year: Yes, prior year finding 2023-005. Recommendation: We recommend that management review procedures and control processes to ensure they comply with the federal requirements noted above. Views of Responsible Officials: Management is in agreement.

Corrective Action Plan

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.

Categories

Questioned Costs Subrecipient Monitoring Reporting Material Weakness

Other Findings in this Audit

  • 1156378 2024-003
    Material Weakness Repeat
  • 1156380 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
94.012 Americorps September 11th National Day of Service and Remembrance Grants 94.012 $1.42M