Finding 1214609 (2025-001)

Material Weakness Repeat Finding
Requirement
L
Questioned Costs
-
Year
2025
Accepted
2026-05-13

AI Summary

  • Core Issue: The Organization failed to report subawards over $30,000 to the FFATA Subaward Reporting System on time, violating federal requirements.
  • Impacted Requirements: Compliance with 2 CFR 170.200 and FFATA mandates timely reporting of subawards, which was not met.
  • Recommended Follow-Up: Continue monitoring subrecipients and enhance training and internal reviews to ensure timely compliance with FFATA reporting.

Finding Text

Finding 2025-001 U.S. Department of Health and Human Services Program Title: Global AIDS Assistance Listing Number: 93.067 Federal Award Year: 2024-2025 Type of Finding: Reporting – Internal Control and Compliance (Material Weakness) Criteria: In accordance with 2 CFR 170.200 and the Federal Funding Accountability and Transparency Act (FFATA) requirements, recipients of federal grants are required to report subawards of $30,000 or more to FSRS no later than the end of the month following the month in which the subaward was obligated. Condition: During the audit of the Organization for the fiscal year ending September 30, 2025, it was noted that the Organization did not timely file the FFATA subaward reports. Specifically, subawards exceeding $30,000 were not reported in the FFATA Subaward Reporting System by the end of the month following the month in which the subaward was obligated or the beginning of the fiscal year for continuing awards. Cause: Management became aware of this requirement midway through the fiscal year. At that point, management implemented a process to ensure the information was reported. As a result, while the information was reported accurately, it was not reported timely. Effect: Failure to comply with FFATA requirements reduces the transparency and accountability of federal spending and may impact future funding or trigger additional monitoring. Questioned Costs: None to report. Identified as a Repeat Finding: This finding was reported as Finding 2024-005. Recommendation: We recommend that the Organization continue to monitor new and existing subrecipients to ensure compliance with FFATA reporting requirements. Views of Responsible Officials: Management concurs with the finding. The Organization acknowledges the oversight in not reporting subawards exceeding $30,000 in the FFATA Subaward Reporting System (FSRS), which was due to a lack of awareness regarding this specific requirement after hand-over transitions to new staff. To address this, the Organization has implemented formal procedures to ensure full compliance with all FFATA reporting. These include clearly defined responsibilities and training of relevant staff and internal reviews to ensure timely submission of required reports. The organization is committed to strengthening internal controls to ensure transparency, maintain compliance with federal grant regulations, and prevent recurrence of this issue. Responsible Person: Director, Ethics & Compliance.

Corrective Action Plan

Finding 2025-001: Reporting - Other Finding Required to be Reported under Uniform Guidance View of Responsible Officials and Planned Corrective Action: Management concurs with the finding. The Organization acknowledges the oversight in not reporting subawards exceeding $30,000 in the FFATA Subaward Reporting System (FSRS), which was due to a lack of awareness regarding this specific requirement after hand-over transitions to new staff. To address this, the Organization developed formal procedures to ensure full compliance with all FFATA reporting. These include clearly defined responsibilities and training relevant staff and internal reviews to verify ongoing compliance, to ensure timely submission of required reports. The organization is committed to strengthening internal controls to ensure transparency, maintain compliance with federal grant regulations, and prevent recurrence of this issue. Name of contact person: Name: Michael Woliver Title: Senior Director, Compliance & Operations Contact: MWoliver@cmmb.org Proposed Completion Date : September 30, 2025, and ongoing

Categories

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1214606 2025-001
    Material Weakness Repeat
  • 1214607 2025-001
    Material Weakness Repeat
  • 1214608 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
98.006 FOREIGN ASSISTANCE TO AMERICAN SCHOOLS AND HOSPITALS ABROAD (ASHA) $265,025
98.001 USAID FOREIGN ASSISTANCE FOR PROGRAMS OVERSEAS $92,670
93.067 GLOBAL AIDS $48,450