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Finding 2024-004 Finding Type: Noncompliance and significant deficiency in internal control Federal Department: U.S. Department of Health and Human Services, Centers for Disease Control and Prevention Identification of the Federal Program: Assistance Listing Number 93.988 – Cooperative Agreements for Diabetes Control Programs Award Number: NU58DP007394 Compliance Requirement(s): Reporting Criteria: Federal Funding Accountability and Transparency Act Aspects of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202 of Pub. L. No. 110-252, which relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient); however, the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement. Direct recipients are required to report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds. Prime contractors are required to report each first-tier subcontract award of $30,000 or more in federal funds. Grant and cooperative agreement recipients and contractors are required to register in FSRS and report subaward data through FSRS. To do so, they will first be required to register in the System for Award Management (SAM) (if they have not done so previously for another purpose (e.g., submission of applications through Grants.gov) and actively maintain that registration. Prime contractors have previously been required to register in SAM. Information input to FSRS is available at USASpending.gov as the publicly available website for viewing this information (https://www.usaspending.gov/search). Certain key data elements are required to be reported on the Federal Funding Accountability and Transparency Act (FFATA) report via the FSRS system. Per the 2025 OMB Compliance Supplement, the amount of subaward is defined as, “the net dollar amount of federal funds awarded to the subawardee including modifications.” Condition: During the current audit period, the Imperative did not comply with its FFATA reporting requirements as outlined in its grant agreement and federal regulations. We selected six AL# 93.988 subawards for testing from a population of six subawards and noted the absence of submission. The total federal funds of the six subawards amounted to $575,000 per the subaward agreements. The exceptions are summarized in the chart below. Cause: Due to oversight, the Imperative did not submit FFATA reports via the Federal Subaward Reporting system (FSRS). Effect: Failure to prepare and submit the required reports is a violation of federal regulations and impairs the grantor agency’s ability to adequately monitor the program activities/federally funded program. Questioned Costs: None. Repeat Finding: Not applicable. Recommendation: We recommend that the Imperative implement procedures to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: See management’s corrective action plan.