Finding 1204829 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-03-30

AI Summary

  • Core Issue: There are significant deficiencies in internal controls over compliance with FFATA reporting requirements.
  • Impacted Requirements: Timely and accurate submission of subaward information in the Federal Subaward Reporting System (FSRS) is mandated by the FFATA.
  • Recommended Follow-Up: Implement formal policies and procedures for tracking and reporting FFATA requirements, including review and monitoring controls.

Finding Text

Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: (1) Injury Prevention and Control Research and State and Community Based Programs (2) Community Programs to Improve Minority Health Grant, and (3) Ending the HIV Epidemic in the U.S. – Ryan White HIV/AIDS Program Parts A and B Assistance Listing Number: (1) 93.136, (2) 93.137, and (3) 93.686 Federal Award Identification Number and Year: (1) NH28CE003349, NH28CE003545, (2) CPIMP211244, CPIMP221343, CPIMP231370, and (3) UT8HA33922 Award Periods: (1) September 1, 2021 – August 31, 2026, and September 1, 2023 – August 31, 2028, (2) September 30, 2022 – September 29, 2027, (3) March 1, 2020 – February 28, 2025, and March 1, 2025 – February 28, 2030 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or specific requirement: The Federal Funding Accountability and Transparency Act (FFATA) requires non‑Federal entities to report required subaward information in the Federal Subaward Reporting System (FSRS) for each subaward meeting the reporting threshold. Subaward information must be reported no later than the last day of the month following the month in which the subaward was made. Condition: Adequate internal controls were not in place to ensure FFATA reports were submitted timely and properly for all subawards that meet the FFATA reporting requirements. Questioned costs: None Context: During our testing of FFATA reporting, we noted the following: - For AL #93.136 and AL #93.137, 4 of the 5 FFATA subaward reports tested were submitted after the required deadline, as the reports were not entered into FSRS by the end of the month following the subaward date. - For AL #93.686, FFATA subaward reports were not submitted for 7 of the 7 subrecipients that met FFATA reporting requirements. Cause: The Commission did not have procedures in place to ensure FFATA subaward reporting was completed timely and consistently for all applicable programs and subrecipients. Effect: Failure to submit FFATA reports timely and completely results in noncompliance with federal reporting requirements and reduces transparency over the use of federal funds. Recommendation: We recommend that management implement formal policies and procedures to ensure FFATA reporting requirements are identified, tracked, and reported timely for all applicable subawards. This should include documented review procedures and monitoring controls to ensure FFATA reports are submitted accurately and within required deadlines. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Injury Prevention and Control Research and State and Community Based Programs– Assistance Listing No. 93.136 Community Programs to Improve Minority Health Grant– Assistance Listing No. 93.137 Ending the HIV Epidemic in the U.S. – Ryan White HIV/AIDS Program Parts A and B Assistance Listing No. 93.686 Recommendation: We recommend that management implement formal policies and procedures to ensure FFATA reporting requirements are identified, tracked, and reported timely for all applicable subawards. This should include documented review procedures and monitoring controls to ensure FFATA reports are submitted accurately and within required deadlines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: BPHC will update our FFATA Reporting Standard Operating Procedures (SOP) to include tighter controls that ensure that FFATA reporting requirements are more clearly identified, tracked and reported timely for all applicable subawards. The updated SOP will document the revised procedures and require a biweekly or monthly sign off from the Director of the Post-Award Grant Accounting to ensure that our FFATA reporting is accurate and on time going forward. Name(s) of the contact person(s) responsible for corrective action: Jose A. Hernandez and Steve Simmons Planned completion date for corrective action plan: Prior to June 30, 2026

Categories

Subrecipient Monitoring

Other Findings in this Audit

  • 1204824 2025-001
    Material Weakness Repeat
  • 1204825 2025-001
    Material Weakness Repeat
  • 1204826 2025-001
    Material Weakness Repeat
  • 1204827 2025-001
    Material Weakness Repeat
  • 1204828 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.914 HIV EMERGENCY RELIEF PROJECT GRANTS $13.43M
93.686 ENDING THE HIV EPIDEMIC: A PLAN FOR AMERICA — RYAN WHITE HIV/AIDS PROGRAM PARTS A AND B $2.76M
93.967 CENTERS FOR DISEASE CONTROL AND PREVENTION COLLABORATION WITH ACADEMIA TO STRENGTHEN PUBLIC HEALTH $2.47M
93.495 COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $1.61M
93.136 INJURY PREVENTION AND CONTROL RESEARCH AND STATE AND COMMUNITY BASED PROGRAMS $1.41M
93.137 COMMUNITY PROGRAMS TO IMPROVE MINORITY HEALTH $1.07M
93.069 PUBLIC HEALTH EMERGENCY PREPAREDNESS $891,165
93.926 HEALTHY START INITIATIVE $855,023
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $721,262
16.045 COMMUNITY-BASED VIOLENCE INTERVENTION AND PREVENTION INITIATIVE $624,100
93.334 THE HEALTHY BRAIN INITIATIVE: TECHNICAL ASSISTANCE TO IMPLEMENT PUBLIC HEALTH ACTIONS RELATED TO COGNITIVE HEALTH, COGNITIVE IMPAIRMENT, AND CAREGIVING AT THE STATE AND LOCAL LEVELS $578,086
14.267 CONTINUUM OF CARE PROGRAM $575,553
97.067 HOMELAND SECURITY GRANT PROGRAM $519,704
93.304 RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH $472,040
93.889 NATIONAL BIOTERRORISM HOSPITAL PREPAREDNESS PROGRAM $428,684
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $354,331
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $194,240
16.842 OPIOID AFFECTED YOUTH INITIATIVE $194,039
93.788 OPIOID STR $188,972
17.285 REGISTERED APPRENTICESHIP $181,604
93.917 HIV CARE FORMULA GRANTS $173,596
93.994 MATERNAL AND CHILD HEALTH SERVICES BLOCK GRANT TO THE STATES $166,934
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $135,439
93.107 AREA HEALTH EDUCATION CENTERS $133,511
10.569 EMERGENCY FOOD ASSISTANCE PROGRAM (FOOD COMMODITIES) $130,872
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $125,528
16.548 DELINQUENCY PREVENTION PROGRAM $111,315
14.239 HOME INVESTMENT PARTNERSHIPS PROGRAM $92,230
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $66,100
93.135 CENTERS FOR RESEARCH AND DEMONSTRATION FOR HEALTH PROMOTION AND DISEASE PREVENTION $57,613
93.104 COMPREHENSIVE COMMUNITY MENTAL HEALTH SERVICES FOR CHILDREN WITH SERIOUS EMOTIONAL DISTURBANCES (SED) $52,080
93.884 PRIMARY CARE TRAINING AND ENHANCEMENT $37,473
93.217 FAMILY PLANNING SERVICES $32,677
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $31,169
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION’S HEALTH $13,249
16.888 CONSOLIDATED AND TECHNICAL ASSISTANCE GRANT PROGRAM TO ADDRESS CHILDREN AND YOUTH EXPERIENCING DOMESTIC AND SEXUAL VIOLENCE AND ENGAGE MEN AND BOYS AS ALLIES $12,379
97.000 STATE 911 TRAINING GRANT $7,851
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $-80,500