Finding Text
Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “FFATA” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: We were unable to determine if internal controls were in place during 2023 to ensure FFATA reporting was performed, and subawards entered into by Reinvestment Fund, Inc. over $30,000 were not reported. Cause The Organization’s federal grant compliance controls did not address the general administrative controls over ensuring FFATA reporting is performed as required. Effect or Potential Effect: FFATA reporting was not performed timely and accurately. Questioned Costs: None Context: Reinvestment Fund, Inc. had 98 subawards that met the FFATA requirements which were not reported. The federal award identification numbers (FAIN) for the awards is pending from the USDA and is required to complete the FFATA reporting. Identification as a Repeat Finding: No Recommendation: We recommend that Reinvestment Fund, Inc. implement policies and procedures to review FFATA reporting and maintain documentation of internal controls as well as provide training to staff on FFATA reporting requirements. Views of Responsible Officials: The Organization acknowledges that we should have been filing information for all of our grantees over $30,000 on the FFATA Sub-award Reporting System website. We have a remediation plan in place to ensure that all past grantees over $30,000 are registered on the website, and we have included FFATA registration as a step in the creation of all future HFFI grantees.