Finding 1156465 (2024-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-09-29

AI Summary

  • Core Issue: The Foundation failed to submit required FFATA reports for a subaward contract exceeding $30,000.
  • Impacted Requirements: Compliance with FFATA reporting criteria, specifically 2 CFR Part 170, was not met.
  • Recommended Follow-Up: Implement a formal process to ensure timely submission of FFATA reports for future subawards meeting the $30,000 threshold.

Finding Text

Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting Criteria Reporting subaward and executive compensation information in accordance with the Federal Funding Accountability and Transparency Act of 2006 (FFATA), codified in 2 CFR Part 170. Condition During our audit for the year ended December 31, 2024, we tested a subaward contract under which FFATA reporting was required but not submitted. First tier subawards of $30,000 or more must be submitted to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the end of the month following the month in which the subaward was issued. Effect As a result, the Foundation was not in compliance with reporting requirements under FFATA. Recommendation We recommend that the Foundation submit the FFATA report. Additionally, a formal process should be implemented to ensure timely submission of future reports whenever the $30,000 subaward threshold is met. Views of Responsible Officials Management agrees with the finding and recommendation. See corrective action plan.

Corrective Action Plan

Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the auditor's recommendations and further acknowledges that a subaward contract under which FFATA reporting was required was not submitted within the required 30 days after the subaward was executed. 2. Corrective Action FFATA Reporting: Wadhwani Institute for Artificial Intelligence Foundation (WIAI) is working to gain access to the SAM.gov reporting capabilities for the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) to ensure proper reporting for any and all required FFATA reporting is met for new federal subawards. Process Enhancement: WIAI will ensure comprehensive reporting processes for federal grants are in place prior to engaging as a prime or subrecipient, including tracking reporting and other significant deadlines. 2024 Finding Resolution: The specific grant referenced in this finding was terminated in January 2025. The awarding agency (USAID) has since been functionally dismantled by the Trump administration, with 83% of programs eliminated as of March 2025 and remaining functions transferred to the State Department. Given the agency's operational dissolution and the grant's termination, late FFATA reporting for the 2024 subaward is not feasible through normal channels. Management will monitor for any guidance from the State Department regarding reporting obligations for grants from the former USAID structure. 3. Timeline FSRS Access: Target completion by December 2025 (pending SAM.gov registration resolution) Process Documentation: Within 60 days of FSRS access being obtained Full Implementation: Upon receipt of next federal subaward requiring FFATA reporting Ongoing Monitoring: Monthly grant reviews and comprehensive year-end validation Prepared by: Ann Marie Ilibasic, Grants & Compliance Consultant Reviewed by: David Martin, Audit Committee Chair Next Review Date: Fiscal Year End 2025

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 1156464 2024-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $2.49M