Finding Text
2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA) / Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster — Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) — FFATA / Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Criteria Under the Transparency Act award term (2 CFR Part 170 Appendix A), recipients must report each first-tier subaward action subject to FFATA in SAM.gov no later than the end of the month following the month in which the subaward obligation was made. Condition During testing of FFATA special reporting under Reporting (L), we noted two first-tier subaward actions that were submitted in SAM.gov after the required reporting timeframe (subaward dates 9/11/2024 and 1/9/2025; SAM.gov submission date 4/16/2025). Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Effect / Potential Effect Late FFATA reporting reduces the timeliness of public transparency and federal oversight information available in SAM.gov/USAspending and may increase the risk of noncompliance with federal reporting requirements; however, the matters noted did not result in questioned costs and did not affect allowability of program expenditures. Cause Management explained that the late submissions were primarily due to the federal FSRS→SAM.gov transition, including delayed federal training (Jan/Feb 2025), difficulties obtaining system access/roles, preloaded data errors in SAM.gov causing report rejections, backlogs in SAM.gov support, and staff turnover, which collectively delayed timely submission. Recommendation We recommend that SCOE continue its current FFATA reporting practices, including timely identification of first‑tier subawards subject to FFATA and submission of required data in SAM.gov, and continue maintaining documentation of reporting efforts (e.g., submission confirmations, rejection notices, and support ticket correspondence) when federal system changes or external access/data issues occur. Based on management’s explanation and the nature of the federal FSRS‑to‑SAM.gov transition challenges encountered during the period, SCOE’s response efforts (including follow‑up with SAM.gov support and corrective resubmissions as needed) appear appropriate; accordingly, no additional process changes are recommended beyond continuing the established procedures and retention of supporting evidence to demonstrate compliance in periods of federal system disruption. Questioned Costs None. Repeat Finding No. Views of Responsible Officials We acknowledge the instances of late FFATA first‑tier subaward reporting identified by the auditors. We believe the delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. We took reasonable and timely steps to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. We consider this condition isolated to the federal system transition period and not indicative of a systemic breakdown in our reporting processes. We intend to continue our existing FFATA reporting procedures and will continue to retain appropriate documentation of submissions and related system communications to support compliance during future federal reporting system changes.