Finding Text
II. Federal Award Findings and Questioned Costs Finding 2025-002: Failure to Report Required Subawards Under FFATA Federal Program: Program Name: AmeriCorps State and National Service Program, Assistance Listing: 94.006 III. Federal Award Findings and Questioned Costs, Continued .Finding 2025-002: Failure to Report Required Subawards Under FFATA, Continued Criteria:The Federal Funding Accountability and Transparency Act (“FFATA”), as implemented through 2 CFR Part 170, requires prime recipients of federal grants and cooperative agreements to report first-tier subawards of $30,000 or more, including amendments to subawards that increase the total obligated above the $30,000 threshold in a subsequent year, in SAM.gov (previously in the FFATA Subaward Reporting System (“FSRS”) through March 8, 2025) by the end of the month following the month in which the subaward was obligated. Accurate and complete subaward reporting is required to ensure transparency of federal spending. Failure to report timely constitutes noncompliance with the FFATA reporting requirement included in the OMB Compliance Supplement. Condition/Context: During testing of FFATA reporting requirements, we identified that the Organization did not report any of the approximately eleven first-tier subawards meeting the reporting threshold under the prime award received under its grant agreement with AmeriCorps; officially the Corporation for National and Community Service. Cause: The Organization was subject to FFATA reporting requirements under its grant agreements received as a prime recipient directly from AmeriCorps. The cause of the FFATA reporting lapses was a requirements-interpretation gap in a grant agreement context, and management has agreed to promptly remediate and implement controls. The noncompliance resulted from a good-faith misunderstanding regarding the applicability of FFATA to the grant agreement and did not stem from intentional misconduct or an overall deficient control environment. Effect: Failure to report subawards in FSRS/SAM.gov may reduce the transparency of federal spending and result in noncompliance with FFATA requirements. Incomplete federal reporting could impair the ability of oversight bodies to effectively track federal funds. AmeriCorps maintained visibility and comprehensive oversight through other reporting submitted by the Organization to AmeriCorps including proposals (with subrecipient budgets), quarterly financial reports and annual subaward certifications. AmeriCorps oversight was further evidenced by the annual Notice of Grant Awards provided under the grant agreement. These mechanisms provided effective oversight, notwithstanding FFATA lapses, and did not result in obscuring where funds went, impeding oversight, and/or failing to provide information that would influence federal decision-making. Questioned Costs: None. FFATA reporting is a compliance requirement related to transparency, and no direct financial impact was identified. Repeat Finding: No. III. Federal Award Findings and Questioned Costs, Continued: Finding 2025-002: Failure to Report Required Subawards Under FFATA, Continued Recommendation: We recommend the Organization establish written internal controls, including procedures and tracking mechanisms to ensure timely FFATA reporting, as well as provide training to grants management personnel responsible for FFATA submissions to ensure timely and accurate reporting. Further, the Organization should complete the FFATA reporting for the subawards promptly at the time a new subaward agreement for $30,000 or more is signed or when an amendment for a previous subaward increases the amount over the $30,000 threshold. Management Response: Management concurs with the finding. The Organization acknowledges lapses in timely reporting of first-tier subawards in the FSRS/SAM.gov and gaps in internal controls, including procedure documentation, tracking of subaward obligation dates, and staff training. The Organization is in the process of establishing written internal controls, including procedures and tracking mechanisms to ensure timely FFATA reporting, as well as providing training to grants management personnel responsible for FFATA submissions to ensure timely and accurate reporting. The overdue FSRS/SAM.gov reports will be submitted, and AmeriCorps will be provided with documentation of completion. Management notes that all other financial and performance reporting requirements which included subaward information for the aforementioned subawards were filed timely.