Finding 1215850 (2025-002)

Reporting – Federal Funding Accountability and Transparency Act Management’s Views and Corrective Action Plan Management’s Views and Opinion Sunset Park Health Council, Inc. acknowledges the finding related to Federal Funding Accountability and Transparency Act (FFATA) reporting for subaward actions under the Community Health Centers, Section 330, Federally Qualified Health Center Program, Assistance Listing Number 93.224. Management agrees that FFATA reporting requirements apply to subaward actions that obligate $30,000 or more in federal funds and that applicable subaward actions should be reported in the Federal Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward obligation occurs. Management notes that the finding resulted from a process limitation in which FFATA review procedures focused primarily on newly executed subaward agreements and did not fully capture subsequent funding obligations, amendments, or continuation funding actions under existing subaward agreements. Management further notes that there were no questioned costs and that this is not a repeat finding. Sunset Park is committed to strengthening its FFATA identification, review, documentation, and reporting process to ensure that all applicable subaward actions, including those under existing agreements, are evaluated and reported timely in accordance with FFATA and 2 CFR Part 170. Corrective Action Plan To address this finding, Sunset Park will implement the following corrective actions: 1. FFATA Applicability Review for All Subaward Actions The Grants Fiscal Department will review all federally funded subaward agreements, amendments, continuations, and funding obligation actions to determine whether the FFATA reporting threshold has been met. This review will include both newly executed subaward agreements and funding actions under existing subaward agreements. 2. FFATA Reporting Checklist A standardized FFATA checklist will be implemented for each federal subaward action. The checklist will document the Assistance Listing Number, federal award identification, subrecipient name, subaward amount, obligation date, reporting threshold determination, and FSRS reporting status. 3. Monthly Subaward Obligation Review The Director of Grants and assigned Grant Accountant will conduct a monthly review of federal subaward activity to identify any subaward obligation, amendment, or continuation action that requires FFATA reporting. Any reportable action will be submitted in FSRS by the end of the month following the month in which the obligation occurred. 4. Coordination With Contracting and Program Staff Grants Fiscal will coordinate with contracting, program leadership, and finance staff to ensure that Grants Fiscal is notified timely of any new subaward agreement, amendment, budget modification, continuation funding, or other action that may create or modify a federal subaward obligation. 5. Documentation and Retention Evidence of FFATA review and FSRS submission will be retained with the applicable subaward file. Documentation will include the completed FFATA checklist, supporting award or subaward documentation, FSRS confirmation, and evidence of management review. 6. Retrospective FY2025 FFATA Review Sunset Park will complete a retrospective review of the FY2025 Section 330 subaward actions identified in the finding and will complete any required FFATA reporting, to the extent permitted by FSRS and applicable reporting requirements. Responsible Parties: • Director of Grants • Grant Accountants • Contracting Department, as applicable • Program Leadership, as applicable Implementation Timeline: Full implementation of corrective actions by August 31, 2026. Training: Grants Fiscal staff will receive training on FFATA reporting requirements, including the identification of reportable subaward actions, timing of FSRS submissions, documentation standards, and the distinction between new subaward agreements and subsequent obligating actions under existing agreements. Training will be incorporated into onboarding for new Grants Fiscal staff. Conclusion: These corrective actions will strengthen Sunset Park’s internal controls over FFATA reporting by ensuring that all applicable federal subaward actions are identified, reviewed, documented, and reported timely. Management believes these actions will address the root cause of the finding and support ongoing compliance with FFATA and Uniform Guidance requirements. Responsible Individual Leonardo Arias