Finding 1207129 (2025-001)

Finding Number: 2025-001 Federal Program: Housing Opportunities for Persons with Aids, Ending the HIV Epidemic: A Plan for America Federal Award Identification Number: OHH22F003; OHH23F003; OHH24F003; UT833926 Assistance Listing Number (ALN): 14.241, 93.686 Federal Awarding Agency: Department of Housing and Urban Development, Department of Health and Human Services Compliance Requirement: Reporting Pass-through Entity: Direct Award Repeat Finding: Yes (AL 14.241) and No (AL 93.686) Prior Audit Finding Number: 2024-003 (AL 14.241) Material Weakness and Material Noncompliance – Federal Funding Accountability and Transparency Act Reporting Criteria The Federal Funding Accountability and Transparency Act (Transparency Act – “FFATA”), as codified in 2 CFR Part 170, requires prime recipients of Federal awards to report first-tier subawards of $30,000 or more in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and, effective March 8, 2025, the System for Award Management website (SAM.gov). Recipients must report these subawards by the end of the month following the month in which the obligation is made. As a direct recipient of Federal funding, the City of Columbus is responsible for ensuring subaward information is reported completely, accurately, and timely in accordance with these requirements. Management is also responsible for establishing and maintaining internal controls to ensure compliance with applicable laws and regulations. Condition During the audit period, the City disbursed approximately $1.58 million under AL #14.241 (Housing Opportunities for Persons with AIDS – “HOPWA”) to four first-tier subrecipients, each exceeding the $30,000 reporting threshold. However, none of these subawards were reported in FSRS/SAM.gov as required. Reporting responsibilities were assigned to the Department of Finance and Management until a new policy, effective May 1, 2025, was put into place transitioning FFATA reporting responsibility for the HOPWA program to the Department of Development. All subawards under this program were executed prior to May 1, 2025. During the audit period, the City disbursed approximately $1.75 million under AL #93.686 (Ending the HIV Epidemic: A Plan for America) to eight first-tier subrecipients, each exceeding the $30,000 reporting threshold, and two of which were selected for testing. Neither of the subawards tested were reported in FSRS/SAM.gov as required. Reporting responsibilities are assigned to Columbus Public Health, which did not submit the required data for this program. Cause The Departments lacked adequate internal controls over the preparation, review, and submission of FSRS/SAM.gov reports, resulting in the omission of required subaward reporting. Effect Failure to report subawards as required results in noncompliance with Federal transparency requirements. This increases the risk of incomplete or inaccurate public reporting and may lead to potential sanctions, including reduced or withheld Federal funding. Additionally, users of Transparency Act data may rely on incomplete information. Recommendation The City should strengthen internal controls over the FSRS/SAM.gov reporting process to ensure all applicable subawards are reported timely and accurately. This should include procedures to identify reportable subawards, assign clear reporting responsibilities, and perform supervisory review of submissions. The City should also implement a reconciliation process between internal records and FSRS/SAM.gov data and periodically evaluate these controls to ensure ongoing compliance with Federal requirements. Officials’ Response: Refer to the Corrective Action Plan.