Finding 1216689 (2024-001)

Finding 2024-001: Timeliness of Reporting During a recent compliance review, it was identified that the organization did not have a formalized process to ensure consistent compliance with the reporting requirements under the Federal Funding Accountability and Transparency Act (FFATA). While the organization maintains strong financial management and grant oversight practices, FFATA-specific procedures had not been explicitly incorporated into written policies, subrecipient agreements, or monitoring tools. Name of Contact Person: Emily Stewart, Chief Executive Officer Applicable Requirement FFATA requires prime recipients of federal funding to report certain subaward and executive compensation information to the federal government to promote transparency in the use of federal funds. These requirements are implemented through federal grant regulations including 2 CFR Part 170 and applicable provisions within 45 CFR Part 75. Corrective Actions Plan: To address this issue and strengthen compliance controls, the organization has implemented the following corrective actions: 1. Retroactive Reporting Completion The organization conducted a comprehensive review of all applicable federal awards. All required FFATA subaward reports from FY19 through the present have been entered into SAM.gov to ensure full compliance with federal reporting requirements. 2. Policy Updates Financial policies and procedures are being updated to include specific guidance regarding FFATA reporting requirements and internal responsibilities for ensuring compliance. 3. Contract Amendments Existing subrecipient agreements have been amended to include an attestation that they are compliant with FFATA requirements and 2 CFR 200. Amended contracts were distributed to all applicable subrecipients to ensure compliance with federal reporting obligations. 4. Subrecipient Monitoring Enhancements The organization has updated its subrecipient monitoring checklist to include verification of FFATA-related compliance requirements as part of ongoing oversight activities. 5. Training and Capacity Building Development staff and the Grants Accountant have registered for a training sponsored by the Department of Justice titled “Pass-through Entity’s Oversight Responsibilities for Subrecipients.” They attended the training online on Wednesday, March 25 2026. We are actively seeking additional compliance training to ensure staff fully understand FFATA requirements and any related compliance obligations. This step is intended to supplement existing financial compliance training and confirm that no additional requirements have been overlooked. Ongoing Monitoring The organization will monitor implementation of these corrective actions and incorporate FFATA compliance into routine grant management and subrecipient monitoring processes moving forward. Conclusion These corrective measures are intended to strengthen internal controls, improve transparency, and ensure full compliance with federal grant reporting requirements going forward. Anticipated Completion Date: Immediately