Finding 1165248 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2025-12-17

AI Summary

  • Core Issue: The recipient failed to submit a required FFATA report for a subaward over $30,000 within the 30-day deadline.
  • Impacted Requirements: Compliance with 2 CFR §200.301 for timely reporting of subawards is not being met, risking federal transparency.
  • Recommended Follow-Up: Enhance monitoring controls and implement a completeness check to ensure all reports are submitted on time.

Finding Text

Federal Award Findings and Questioned Costs 2025-001- Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Sponsoring Agency: National Endowment for the Humanities Assistance Listing Number: 45.164 Award Number: TR-297125-24 Award Year: 2024-2025 Criteria: 2 CFR §200.301 requires recipients to report subaward information for all subawards of $30,000 or more using the FFATA Subaward Reporting System (FSRS) within 30 calendar days after the subaward is made. Condition: During our testing of compliance with federal reporting requirements it was noted that the recipient did not submit a required FFATA report for a subaward that exceeded $30,000 in a timely manner. Specifically, the report for subaward number K209255, issued under the federal award dated June 1, 2024, was not submitted to FSRS within the 30-day deadline. Cause: The recipient’s established control for monitoring subaward agreements subject to FFATA reporting failed due to a manual process for tracking executed subrecipient agreements, resulting in one missed report filing during the fiscal year. Effect: Delays in FFATA reporting reduce federal transparency and may result in noncompliance with federal statutory and regulatory requirements. This noncompliance could potentially lead to federal sanctions or loss of funding if not corrected. Questioned Costs: Not applicable. Recommendation: We recommend the recipient expand their control to include a completeness check against their systems of record and implement other process oversight changes to ensure all applicable reports are submitted prior to the 30-day deadline. Repeat Finding in the Prior Year: Not applicable. Management’s Views and Corrective Action Plan: See Management’s Views and Corrective Action Plan included in this report.

Corrective Action Plan

Management's Views and Corrective Action Plan 2025-001- Compliance with Federal Funding Accountability and Transparency Act (FFATA) Reporting Sponsoring Agency: National Endowment for the Humanities Award Name: American Experience, A Man Called White Award Number: TR-297125-24 Assistance Listing Title: Promotion of the Humanities Public Programs Assistance Listing Number: 45.164 Award Year: 2024-2025 Management's Views and Corrective Action Plan WGBH Educational Foundation (“the Foundation”) concurs with this finding. During fiscal year 2025, the Foundation identified a control failure with their established FFATA reporting control. After thorough review of active subaward agreements, the Foundation identified one contract that was not reported timely. Due to the grant's termination date of April 2, 2025, the Foundation was not able to file the report through SAM.gov. However, the Foundation promptly reached out to the National Endowment for Humanities (NEH) for assistance with filing. At this time, the Foundation has not received a response from NEH on next steps. The Foundation has since enhanced its control to include a three-way reconciliation using system generated reports to validate completeness of the Foundation’s monthly list of executed subaward agreements prior to reporting deadline. In addition to the reconciliation, the Foundation has implemented a FFATA process checklist which captures the process steps, applicable contract execution date(s), report submission date(s) and sign off/approval of the monthly process. A secondary review and approval of the process have been included in the updated control. The enhanced control was implemented for the September 2025 FFATA reporting. Contact person: Katie Dillon Managing Director, Production Finance and Grants Compliance 617-300-3829

Categories

Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
84.305 EDUCATION RESEARCH, DEVELOPMENT AND DISSEMINATION $382,086
45.164 PROMOTION OF THE HUMANITIES PUBLIC PROGRAMS $377,835
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $79,545
45.312 NATIONAL LEADERSHIP GRANTS $19,146
45.313 LAURA BUSH 21ST CENTURY LIBRARIAN PROGRAM $15,684
84.295 READY-TO-LEARN TELEVISION $14,284