Finding Text
Criteria: Under the Federal Funding Accountability and Transparency Act (“FFATA”), as amended and codified in 2 CFR Part 170, direct recipients of federal grants and cooperative agreements are required to report first-tier subawards of $30,000 or more. These reports will be submitted in SAM.gov, and the required information must be reported no later than the last day of the month following the month in which the subaward obligation or modification occurs. Condition: During the fiscal year ended September 30, 2025, Pact awarded a total of 298 subawards exceeding $30,000 to subrecipients for assistance listing number 98.001. Refer to the table below for the results of our testing. Cause: While Pact Inc. has established policies and procedures to ensure required reports are accurately completed and submitted on a timely basis, the report was not submitted timely due to a gap in the FFATA reporting process. Specifically, subaward modifications finalized in the subaward system were not timely captured, and the control in place did not identify the omission in a timely manner. Effect or potential effect: Failure to comply with FFATA requirements may result in noncompliance with federal transparency requirements and may subject the organization to increased federal oversight and potential enforcement actions. Questioned Costs: None. Context: This a condition identified based upon our review of Pact’s compliance with the specified requirements. Recommendation: We recommend that Pact Inc. strengthen their internal controls over the reporting process to ensure all FFATA reports are submitted within the required timeframe. Views of Responsible Officials: Management recognizes the importance of timely FFATA reporting and has already implemented corrective actions to prevent future delays in entering sub-award data. Management further notes that the simultaneous termination of numerous USG-funded projects during FY 2025 necessitated a rapid but responsibly managed furlough and reduction in force. While management maintains an expectation of 100 percent timely reporting and acknowledges that any delayed entry is significant, the occurrence of a single delay under these extraordinary circumstances is understandable.