Finding 1168793 (2025-001)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-01-12
Audit: 380925
Organization: Mississippi First INC (MS)

AI Summary

  • Core Issue: Subaward information over $30,000 was not reported to FSRS, violating FFATA requirements.
  • Impacted Requirements: Timely reporting of subawards is essential for compliance and transparency under 2 CFR 200.331 and FFATA.
  • Recommended Follow-Up: Implement formal policies for FFATA reporting, assign responsibility, create checklists, and conduct periodic reviews to ensure compliance.

Finding Text

Criteria: Under 2 CFR 200.331 and the Federal Funding Accountability and Transparency Act (FFATA), pass-through entities are required to report subaward information—including the amount, recipient details, and other necessary data—to the Federal Subaward Reporting System (FSRS). This report must be submitted by the end of the month following the month in which the subaward is issued. Any subaward of $30,000 or more must be reported to FSRS to meet federal compliance requirements. Condition: Subaward information for federal funds exceeding $30,000 was not reported to the Federal Subaward Reporting System (FSRS), as required by FFATA. Cause: The delay in submitting the FFATA report was due to a personnel transition during the reporting period. The outgoing Executive Director had been responsible for the filing, and the incoming staff member and new Executive Director was not yet aware of the reporting requirement. As a result, the report was inadvertently not submitted. We view this as an isolated incident stemming from the timing of the transition and a gap in knowledge transfer. Effect: Not meeting FFATA reporting requirements can impact transparency and may raise questions about costs, which could affect eligibility for future federal funding if not addressed Recommendation: We recommend that management develop and implement formal policies and procedures to ensure timely and accurate FFATA reporting for all subawards of $30,000 or more. These procedures should include assigning responsibility for FFATA reporting to a designated staff member, creating a standardized checklist and timeline for entering subaward data into the Federal Subaward Reporting System (FSRS), and establishing automated reminders or calendar alerts for reporting deadlines. Additionally, periodic internal reviews should be conducted to verify the completeness and timeliness of submissions, helping maintain compliance and transparency. Views of Responsible Officials and Planned Corrective Actions: The Organization is implementing enhancements to its internal control framework governing Federal Funding Accountability and Transparency Act (FFATA) reporting processes. These improvements are designed to ensure timely and accurate submission of subaward data in strict adherence to the requirements set forth in 2 CFR Part 200 (Uniform Guidance).

Corrective Action Plan

Corrective Action Plan June 30, 2025 Finding: 2025-001 Name of Responsible Official: Angela Bass Anticipation Completion Date: December 31 , 2025 Mississippi First's Response: 1. Audit Finding Corrective Action Plan The auditor noted that Mississippi First did not submit a FFATA report for a subaward of $30,000 or more in a timely and accurate manner. 2. Root Cause The delay in submitting the FFATA report was due to a personnel transition during the reporting period. The outgoing Executive Director had been executing FFATA filings, and the incoming Executive Director and was not yet aware of this reporting requirement. Because the requirement was not captured in any written procedures or transition documents, the report was inadvertently missed. This was an isolated incident resulting from the timing of the leadership transition and a gap in knowledge transfer. 3. Corrective Action Taken / Planned A. Formal Policy Development - Mississippi First has drafted a comprehensive FFATA Compliance and Subaward Reporting Policy. B. Assignment of Responsibility - The Director of Operations is designated as the FFATA Reporting Officer. C. FFATA Reporting Checklist - A standardized checklist ensures accuracy for each submission. D. FSRS Standard Operating Procedure (SOP) - A detailed, step-by-step SOP has been developed. E. Deadline Tracking & Automated Reminders - FFATA deadlines will be integrated into the grants management calendar. F. Quarterly Internal Reviews - Quarterly internal audits will verify completeness, accuracy, and timeliness. G. Job Description Updates - Relevant staff job descriptions now include FFATA responsibilities. 4. Timeline for Implementation • Finalize and adopt FFATA Policy- by December 31, 2025 • Assign FFATA Reporting Officer role - Completed • Launch FFATA checklist and SOP - by December 31, 2025 • Implement automated reminders - by December 31, 2025 • Conduct first quarterly compliance review - by December 31, 2025 5. Preventive Measures Mississippi First will require FFATA training, include FFATA in onboarding, review the policy annually, and integrate FFATA compliance into grants management protocols.

Categories

Subrecipient Monitoring Eligibility Reporting Internal Control / Segregation of Duties

Programs in Audit

ALN Program Name Expenditures
84.282 CHARTER SCHOOLS $1.21M