Finding Text
SD 2025-001 REPORTING Department of Commerce ALN 11.463 – Habitat Conservation Federal Award ID Number: FX463C0051 2025 Funding Criteria: Per 2 CFR 200.303, non-Federal entities must establish and maintain effective internal controls over Federal awards that provide reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. In addition, pursuant to 2 CFR Part 170, recipients of Federal awards are required to report first-tier subawards and executive compensation data in accordance with the Federal Funding Accountability and Transparency Act (FFATA). Specifically, subaward information must be reported in the Federal Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward was obligated, as required by the terms and conditions of the Federal award. Condition: The FFATA report was not filed during the year as subawards were granted. Cause: The Council was unaware of the requirement to file the FFATA. Effect: Potential for unintended errors to occur without being immediately identified and corrected. The Council was not in compliance with the Uniform Guidance and the Habitat Conservation Program. Questioned Costs: None. The finding is for reporting which does not relate to questioned costs. Perspective: None of the FFATA reports were filed during 2025 for all 10 subrecipients. Recommendation: The Federal Funding Accountability and Transparency Act (FFATA) reporting requirement is a general term and condition from the Department of Commerce and should be completed as required and reviewed by someone other than the preparer before submission. Management Response: The FFATA reporting requirement was not a specific award condition on the grant award to the IRL Council from NOAA Fisheries. However, it is a standard general term and condition from the Department of Commerce which is referenced on the grant award. The subawards for the NOAA grant have now been input into SAM.gov. The IRL Council will review the specific FFATA requirements required by the Department of Commerce (different than the EPA requirements) and will make sure that the IRL Council continues to be in compliance.