Core Issue: The YMCA failed to report a first-tier subaward through SAM.gov as mandated by 2 CFR Part 170.
Impacted Requirements: This oversight violates the Federal Funding Accountability and Transparency Act (FFATA) reporting obligations.
Recommended Follow-Up: Management should promptly report the missing subaward and create procedures to ensure compliance with federal reporting requirements in the future.
Finding Text
Criteria: The grant agreement and 2 CFR Part 170, implementing the Federal Funding Accountability and Transparency Act (FFATA), requires recipients of applicable federal awards to report qualifying first-tier subawards through SAM.gov. Condition and Context: The YMCA did not report its first-tier subaward to a subrecipient through SAM.gov as required by 2 CFR Part 170. Cause: Management was not aware of the FFATA first-tier subaward reporting requirement. Effect: Required first-tier subaward information was not reported and therefore was not made available through the federal transparency reporting system. Recommendation: Management should complete the required FFATA subaward reporting through SAM.gov and establish procedures to identify and comply with applicable federal reporting requirements.
Corrective Action Plan
We will complete the first-tier subaward reporting through SAM.gov as soon as possible. Additionally, we will review our processes and procedures for identifying all applicable reporting requirements for the YMCA’s federal awards.