FAC Explorer

Finding 1160310 (2023-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2025-10-10
Audit: 370698
Organization: Trailhead Institute (CO)
Auditor: Taylor Roth and Company PLLC

AI Summary

  • Core Issue: Significant deficiency in internal controls over compliance with FFATA reporting requirements for subawards.
  • Impacted Requirements: 2 CFR Part 170 mandates timely reporting of subawards over $30,000 to the FSRS.
  • Recommended Follow-Up: Implement a tracking system to ensure timely submission of FFATA reports to avoid potential funding issues.

Finding Text

2023-001 Reporting Public Health Training Centers Program – Assistance Listing No. 93.516 Award Number: 1 T29HP46735‐01‐00 – Award Period: September 15, 2022 through September 14, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Condition: During our testing of reporting requirements, we noted three subawards for two subrecipients where the Federal Funding and Accountability Transparency Act (FFATA) subaward reports were not filed. The total amount of subawards required to be reported under the major program was $732,965. Criteria: 2 CFR Part 170 requires subawards to be reported to the Federal Funding and Accountability Transparency Act Subaward Reporting System (FSRS). FFATA requires prime grant recipients to file a FFATA subaward report by the end of the month following the month in which the prime recipient awards an initial sub-grant (or subsequent grant modification resulting in a total award) greater than or equal to $30,000. Questioned Costs: None. Cause: The Organization did not have a process in place to ensure FFATA subawards were submitted timely. Effect: Compliance with FFATA reporting is not being met and the information is not being provided on the public website. Noncompliance could result in potential loss or suspension of grant funding. Recommendation: The Organization should implement procedures to comply with the requirements of FFATA including a system to track timely submissions of FFATA reports. Views of Responsible Officials and Planned Corrective Actions: Management agrees. See separately issued Corrective Action Plan.

Corrective Action Plan

Trailhead is establishing a new Compliance Coordinator role to oversee contract compliance processes. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each grant and contract, that all necessary documents are properly filed, and that ongoing monitoring is in place. This role will be responsible for internal monitoring and auditing. This role will ensure that all grant kick-off meeting follow a standard procedure, including a clear understanding of federal requirements. This position will either complete the FFATA themselves or delegate the responsibility to another. This role will have authority for ensuring the procedures are completed. Furthermore, evidence of the completed procedure will be documented and saved in a newly created contracts database. This database is a centralized storage that will be reviewed during internal compliance checks to ensure all required steps have been completed and documented.

Categories

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting Significant Deficiency

Other Findings in this Audit

  • 1160311 2023-002
    Material Weakness Repeat
  • 1160312 2023-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
94.006 Americorps State and National 94.006 $972,678
93.967 Centers for Disease Control and Prevention Collaboration with Academia to Strengthen Public Health $659,736
93.889 National Bioterrorism Hospital Preparedness Program $325,312
93.U01 Community Engagement Research Alliance Against Covid-19 Disparities $279,313
93.350 National Center for Advancing Translational Sciences $248,003
93.310 Trans-Nih Research Support $220,891
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $209,921
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $132,544
93.516 Public Health Training Centers Program $124,424
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $111,958
93.800 Organized Approaches to Increase Colorectal Cancer Screening $75,396
21.019 Coronavirus Relief Fund $75,000
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $35,839
17.268 H-1b Job Training Grants $33,351
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $27,268
21.027 Coronavirus State and Local Fiscal Recovery Funds $26,608
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $11,061
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $3,926
93.397 Cancer Centers Support Grants $2,200