Finding 1176646 (2025-001)

Identification of the Federal Program: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Federal Agency and Program Name: Maternal and Child Health Federal Consolidated Programs (MCH) Assistance Listing #: 93.110 Award: 5 T73MC30767‐09 Award Year(s): 7/1/2024-6/30/2025 Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): 2 CFR 200.303 requires that the non-Federal entity must “(a) establish, document and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).” Under the requirements of the Federal Funding Accountability and Transparency Act (Transparency Act) that are codified in 2 CFR Part 170, “unless the recipient is exempt as provided in paragraph d. of this award term, the recipient must report each subaward that equals or exceeds $30,000 in Federal funds for a subaward to an entity or Federal agency. The recipient must also report a subaward if a modification increases the Federal funding to an amount that equals or exceeds $30,000. All reported subawards should reflect the total amount of the subaward”. The recipient must report each subaward described 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. Condition: During our audit, we noted 3 Federal Funding Accountability and Transparency Act (FFATA) reports, for the subaward modifications made during fiscal year 2025, were not submitted in the FSRS/SAM.gov timely. Cause: Vanderbilt University Medical Center (VUMC) did not have sufficient internal controls to ensure that the required FFATA reports were submitted timely. Effect or Potential Effect: VUMC did not submit the necessary FFATA reports under the MCH project for each first-tier subaward modifications in FSRS/SAM.gov and consequently was not in compliance with the requirements under the Transparency Act. Questioned Costs: $0 Context: Under the MCH program, there were five subrecipients that had a total of five subaward modifications in FY 2025. The three subaward modifications for which FFATA reports were not submitted timely totaled $33,853. Upon eventual submission, we did not identify any errors in the data reported. Total subrecipient’s costs are $326,025 in FY 2025. The total federal expenditures for the MCH program for FY 2025 were $5,760,179. Identification as a Repeat Finding: This is not a repeat finding. Recommendation: We recommend management strengthen its internal controls and procedures over the review of subrecipient awards and modifications to ensure the required FFATA reports are submitted timely to be in compliance with the Federal Transparency Act. Views of Responsible Officials: Management agrees with the finding and has strengthened our internal controls and procedures to ensure required FFATA reports are submitted timely in compliance with the Federal Transparency Act.