Finding 1239272 (2025-002)

Material Weakness Repeat Finding
Requirement
M
Questioned Costs
-
Year
2025
Accepted
2026-09-30

AI Summary

  • Core Issue: Companies failed to report sub-award information as required by OMB and FFATA, missing key details like federal funds and audit requirements.
  • Impacted Requirements: Non-compliance with FFATA reporting and lack of proper monitoring of subrecipients led to incomplete documentation and communication.
  • Recommended Follow-Up: Revise grant management procedures to include subrecipient monitoring and establish a tracking system for FFATA reporting compliance.

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.

Corrective Action Plan

Finding 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) We acknowledge this finding, which was related to staff turnover. We have since communicated to the impacted subrecipient and have inquired of the grantor if there is an opportunity to submit the missing FFATA reporting. To ensure compliance with this requirement going forward, BestSelf Behavioral Health has identified an individual, our Director of Financial Planning and Analysis, who will be responsible for ensuring this reporting is performed in a timely manner. Our Director of Financial Planning and Analysis will review all grants for FFATA reporting requirements upon receipt of a federal award, track all deadlines for any reporting required, and provide a summary of requirements to new program managers.

Categories

Subrecipient Monitoring

Programs in Audit

ALN Program Name Expenditures
93.958 BLOCK GRANTS FOR COMMUNITY MENTAL HEALTH SERVICES $1.29M
14.267 CONTINUUM OF CARE PROGRAM $481,033
16.575 CRIME VICTIM ASSISTANCE $274,915
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $232,679
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $139,379
93.788 OPIOID STR $112,009
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $106,483
93.150 PROJECTS FOR ASSISTANCE IN TRANSITION FROM HOMELESSNESS (PATH) $86,223
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $85,506
10.558 CHILD AND ADULT CARE FOOD PROGRAM $54,282
93.558 TEMPORARY ASSISTANCE FOR NEEDY FAMILIES $50,000
93.778 GRANTS TO STATES FOR MEDICAID $50,000