Finding Text
2025-002 CFDA #14.267 Failure to monitor and report sub-awardees in accordance with the United States Office of Management and Budget (OMB) and Federal Funding Accountability and Transparency Act (FFATA) Criteria: Under OMB, the Companies need to communicate the CFDA number, Federal award date, amount of federal funds obligated to subrecipient, and that the subrecipient is subject to audit requirements. The Companies are also required to monitor subrecipients during the year including reviewing most recent Single Audit reports. Under FFATA, as a prime contract awardee the Companies are required to report certain subaward information to the federal government using the FFATA Subaward Reporting System (FSRS). Condition: As the prime contract awardee, the Companies entered into a subaward contract and did not report the required subaward information using the FSRS. The Companies documented the subaward with a written memorandum of understanding (MOU). The MOU, however, did not indicate the awarded funds were federal, the CFDA number or audit requirements. Context: During the 2025 compliance audit, the auditor attempted to verify the Companies compliance with FFATA reporting requirements. It was determined that the Companies, as the prime contract awardee, did not, for 2025, report a subaward provided under the Youth Homelessness Demonstration Grant (reporting was performed through 2024). While the Companies did receive periodic reporting from the subrecipient, the Companies were not able to provide evidence that all required communications to the subrecipient were made. Cause: During the year, turnover occurred in program management. The Companies’ grant transition procedures did not include communication of subrecipient monitoring and reporting requirements. The Companies also do not have a procedure in place to identify all federal awards that are subject to FFATA reporting. Effect: The Companies did not report a subaward granted under the Youth Homelessness Demonstration Grant or make all required communications in writing to a subrecipient. Recommendation: The Companies should revise its grant management transition procedures to include subrecipient monitoring requirements and implement an agency wide tracking process to ensure the completeness of FFATA reporting. Views of Responsible Official: See management’s Corrective Action Plan on page 37.