Finding 1182161 (2025-002)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-23

AI Summary

  • Core Issue: A subaward reporting requirement under FFATA was not met, leading to reduced transparency and noncompliance.
  • Impacted Requirements: The failure to report subawards of $30,000 or more to the FSRS violates 2 CFR Part 170.
  • Recommended Follow-Up: Implement stronger internal controls, provide mandatory training for staff, and ensure management reviews all subawards for timely FFATA reporting.

Finding Text

Ques􀆟oned Cost $ – Finding No. 2025-002: Repor􀆟ng (Material Weakness) Federal Agency: U.S. Department of Commerce AL Number and Title: 11.029 – TBCP Award Number and Award Year: NT23TBC0290054 2024 Repeat Finding? No Condition During our audit, we tested a non-statistical sample of one subaward and found that the reporting required by Section 2, Full Disclosure of Entities Receiving Federal Funding, of Federal Funding Accountability and Transparency Act (“FFATA”) was not completed. Criteria In accordance with the FFATA and the requirements of 2 CFR Part 170, Appendix A, prime recipients of federal grants are required to report each subaward of greater than or equal to $30,000. Each subaward must be reported to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”) no later than the end of the following month in which the subaward was made. Effect Failure to file required reports reduces transparency on the use of program funds and represents an instance of noncompliance with the requirements of 2 CFR Part 170. Cause and View of Responsible Officials Program personnel incorrectly classified the associated subaward as a contract and were unaware of the FFATA reporting requirement applicable for subawards until the audit. Recommendation We recommend that management should strengthen their internal controls over subaward identification and reporting. This includes mandatory training for staff involved in federal grant administration and a management-level review of all subawards to ensure FFATA reporting is completed timely.

Corrective Action Plan

Finding No. 2025-002: Reporting AL No.: 11.029 Program Title: Tribal Broadband Connectivity Program Grant Award Number: NT23TBC0290054 Condition FFATA report was not filed regarding the UH Subaward for FY 2025 (7/1/2024–6/30/2025). Corrective Action Plan DHHL will work on budget amendments on the Federal side via eRA Commons (with NTIA and NIST oversight). Once Budget amendments are made, DHHL will immediately prepare and submit FFATA report for UH subaward, make additional updates on .gov systems for report submission, and document reason for late submission. DHHL will confirm UH subaward meets FFATA reporting threshold ($30,000 for subawards) and review all other active subawards for FFATA reporting requirements. Moving forward, DHHL will establish procedures for timely FFATA and subaward reporting. DHHL will also review all subawards from past two years for missed FFATA reports and file any additional delinquent reports. Person Responsible Jaren Tengan, Broadband Coordinator And/or Aislen Bacalso, Broadband Coordination Assistant Anticipated Date of Completion The updated reports are subject to the completion and approval of Federal Budget Amendments. DHHL is hopeful that NTIA and NIST will provide feedback and approval by June 2026, and DHHL will immediately prepare and submit FFATA reports for the UH subaward. (Please note this is the first fiscal year DHHL is working with NIST. It is unsure how long budget amendment processes will take.)

Categories

Subrecipient Monitoring Material Weakness Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1182157 2025-001
    Material Weakness Repeat
  • 1182158 2025-002
    Material Weakness Repeat
  • 1182159 2025-003
    Material Weakness Repeat
  • 1182160 2025-001
    Material Weakness Repeat
  • 1182162 2025-003
    Material Weakness Repeat
  • 1182163 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
12.600 COMMUNITY INVESTMENT $3.24M
14.873 NATIVE HAWAIIAN HOUSING BLOCK GRANTS $1.69M
10.760 WATER AND WASTE DISPOSAL SYSTEMS FOR RURAL COMMUNITIES $200,762
11.029 TRIBAL BROADBAND CONNECTIVITY PROGRAM $192,428
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $45,813
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $5,746