Finding 1224465 (2025-001)

Assistance Listing Number, Federal Agency, and Program Name - 66.616 - U.S. Environmental Protection Agency - Environmental and Climate Justice Community Change Grants Program Federal Award Identification Number and Year - 2024-00E04015 Pass-through Entity - N/A Finding Type - Material weakness Repeat Finding - No Criteria - The Federal Funding Accountability and Transparency Act (FFATA) as mended by Section 6202 of Public Las 110-252 requires recipients of federal awards to report data using the FFATA Subaward Reporting System (FSRS) Tool (pre-March 8, 2025) or SAM.gov (post-March 8, 2025). 2 CFR 200.303 requires that recipients and subrecipients receiving federal awards establish, document, and maintain effective internal control over the federal awards that provide reasonable assurance that the recipient or subrecipient is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition - While the System had controls over accumulating the data for inputs into the portal, it did not have an adequate control in place to ensure transactions subject to FFATA reporting were reviewed for completeness and accuracy upon submission. If Questioned Costs Are Not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could Not Be Reported - There were no questioned costs identified. Identification of How Questioned Costs Were Computed - There were no questioned costs identified. Context - The System's internal controls over FFATA reporting were not designed to review submissions of FFATA reports. The System did not have a formal review process to verify the completeness and accuracy of data submitted to SAM.gov, nor did it maintain a reconciliation between the accounting system's subaward records and the information entered into SAM.gov. There were no instances of noncompliance or questioned cost identified related to this lack of control. Cause and Effect - The System has not developed or implemented a review structure over the FFATA reporting process at the time of submission. As a result, the System was at increased risk of submitting inaccurate, incomplete, or untimely FFATA reports. Recommendation - The System should implement controls regarding review of prepared FFATA submissions to ensure that all required subaward data is accurately and timely reported to SAM.gov. Views of Responsible Officials and Planned Corrective Actions - Management concurs with this recommendation. MetroHealth will establish and maintain a log documenting FFATA report submission, with internal reviews of disclosures prior to submission.