Finding Text
Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Identification of the Major Federal Program: U.S. Department of Health and Human Services Assistance Listing Number: 93.067 Assistance Listing Name: Global AIDS Grant Award Number under the Uniform Guidance Requirements: See Schedule of Findings and Questioned Costs for table. Criteria or Specific Requirement: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Subaward Reporting in SAM.gov. The prime awardee is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: We tested HealthXP’s compliance with specific FFATA reporting requirements. Of the six sub-award reports selected for testing, three of the reports with subaward amounts totaling $668,694 were not submitted within the required timeframe. Specifically, the three FFATA reports were filed between 5 and 36 days later than the required filing date. Questioned Costs: There are no known or likely questioned costs. Context: This is a condition based on testing of HealthXP’s compliance with specified requirements. The samples were selected using a non-statistical sampling method. Cause: Although HealthXP has existing internal control policies and procedures ensuring appropriate filing of sub-award information in SAM.gov, it failed to file the FFATA reports on time. Effect: Failure to report subrecipient information in a timely manner can result in lack of transparency and accountability, which is contrary to the intent of FFATA. Such non-compliance also increases the risk of loss of future awards if compliance with the provisions of Uniform Guidance is not met. Repeat Finding: This is not a repeat finding. Recommendation: We recommend that management ensure that all FFATA reports are filed in a timely manner. In addition, management should strengthen the existing internal controls and conduct refresher training to personnel emphasizing timely submission of FFATA reports. Views of Responsible Officials: HealthXP management agrees with the finding and recommendations and will enhance the processes around timely submission of FFATA reports.