Finding Text
Condition The Education Alliance did not timely report seven first-tier subawards subject to the Federal Funding Accountability and Transparency Act (FFATA) to the System for Award Management (SAM.gov). Criteria FFATA, as implemented at 2 CFR Part 170, requires recipients to report each first-tier subaward of $30,000 or more in federal funds to SAM.gov no later than the end of the month following the month in which the subaward was made. FFATA also requires reporting of the total compensation of the recipient’s five most highly compensated executives in certain circumstances. Cause Management did not have effective internal controls in place to identify all subawards subject to FFATA and to ensure required data was submitted to SAM.gov within the prescribed timeframe. Effect Required FFATA information was not available in the federal transparency reporting system in a complete and timely manner, which may limit public access to accurate information regarding the use of federal funds and represents noncompliance with federal award requirements. Questioned Costs No questioned costs were identified. Recommendation We recommend the Education Alliance strengthen internal controls over FFATA compliance by establishing written procedures to identify all first-tier subawards subject to FFATA reporting, assigning responsibility for preparing and reviewing FFATA submissions, maintaining a tracking log of reportable subawards and applicable due dates, and performing periodic supervisory review to confirm all required reports are submitted completely and timely to SAM.gov. Management Response Management will implement corrective actions to ensure compliance going forward, including revising written procedures to identify reportable subawards, assigning responsibility for preparation and review of FFATA submissions, maintaining a tracking log of subawards and reporting deadlines, and performing supervisory reviews to ensure reports are submitted completely and timely. Management will also provide training for relevant personnel and evaluate prior subawards to determine whether any required reports were omitted and will complete any necessary submissions to the extent permitted.