Finding Text
Item: 2025-001 Assistance Listing Number: 17.280 Program: WIOA Dislocated Worker National Reserve Demonstration Grants Federal Agency: U.S. Department of Labor Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: 23A60YP000003 Award Year: September 30, 2023 to September 30, 2026 Compliance Requirement: Reporting - FFATA Criteria: The Federal Funding Accountability and Transparency Act (FFATA), as implemented by OMB at 2 CFR Part 170, requires prime recipients of federal awards to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: The Foundation did not complete the required FFATA reporting in FSRS for applicable first-tier subawards. Questioned Costs: n/a Context: Our testing encompassed the Foundation’s two first-tier subawards made during the audit period that met the FFATA reporting threshold. For each of the two first-tier subawards, we noted that the Foundation did not complete the required FFATA reporting in FSRS. Effect: The Foundation is not in compliance with required FFATA reporting requirements. This is deemed to be a material weakness in internal control over compliance. Cause: The Foundation did not have sufficient internal controls over FFATA reporting. Specific contributing factors included: (a) lack of formal, documented process to identify and track first-tier subawards meeting the FFATA threshold, and (b) limited staff training and awareness of FFATA reporting requirements and timelines. Identification as a Repeat Finding: Not a repeat finding. Recommendation: First, we recommend the Foundation correct missed FFATA reporting by submitting outstanding subaward information to FSRS as soon as possible and communicate with the federal awarding agency as needed. Additionally, we recommend the Foundation establish and document a FFATA reporting policy that defines the FFATA threshold and timing requirements. The Foundation should also assign clear responsibility for FFATA compliance and implement a monthly reconciliation of subaward obligations to FSRS submissions. Lastly, the Foundation should also provide periodic training to grants, procurement, and finance staff on FFATA requirements and FSRS processes. Views of Responsible Officials: Management of the Foundation concurs with the finding. See Corrective Action Plan.