Finding Text
Type of Finding: (F) Significant Deficiency in Internal Control Over Compliance of Federal Awards (G) Instance of Non-compliance related to Federal Awards Federal Award Information Funding Agency: U.S. Department of Defense, passed through the Air Force Research Laboratory Title: New Space New Mexico Small Satellite Manufacturing and Innovation Hub (iHub) AL #: 12.599 Award #: FA9453-21-3-1001 Compliance Requirement: Subrecipient Monitoring Award Period: 06/01/2021-05/31/2026 Questioned Costs: None Noted Condition We tested 2 grant subrecipients of New Space from a population of 2 subrecipients awarded during 2023, totaling $110,721. For 2 of 2 subrecipient files (totaling $110,721), the files did not include (a) documentation supporting submission of subaward contract to FSRF (now SAM.gov at time of testing) (b) documentation supporting submission of subrecipient monitoring and management plan to AFRL (c) documentation supporting submission of subrecipient agreement including scope of work to AFRL. Criteria The terms and conditions of Award No. FA9453-21-3-1001 require submission of specified subaward information by the end of the month following the month the award was made, and require specified subrecipient monitoring reports be submitted no later than 90 days after the award date. Additionally, Uniform Guidance includes requirements addressing subrecipient financial and performance reporting as applicable to the award. Effect Failure to report subawards may result in noncompliance with grant requirements, reduced transparency, and increased risk that subrecipients are not properly monitored. This could lead to questioned costs, potential repayment of funds, or jeopardize future funding. Cause Subaward setup and reporting responsibilities were not assigned and tracked via a standardized checklist; supervisory review and documentation retention controls were not in place. Recommendation New Space should implement formal policies and procedures to ensure all subawards are properly documented and reported to the grantor and related federal online system in accordance with grant requirements. This should include assigning responsibility, implementing tracking mechanisms, conducting periodic reviews for compliance, and maintaining documentation of submission of required information to all sources. Views of Responsible Officials and Planned Corrective Action New Space will implement procedures to ensure subrecipients are properly documented, reported, and monitored in accordance with grant requirements. Each subaward will include a formal agreement and defined scope of work, and required information will be submitted within established timelines. Documentation of submissions and monitoring activities will be maintained, and a tracking process will be used to ensure compliance. The Financial Analyst will manage subrecipient monitoring, with oversight from the Executive Director, and periodic reviews will be conducted. Policy Owner: Financial Analyst; Implementation Date: March 31, 2024