Corrective Action Plan Finding no 2022-001 CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified under 2 CFR 170, requires that information on federal awards, including subaward activities, be made available to the public through a website maintained by the Office of Management and Budget (OMB). Application and Requirements FFATA applies to all US Government (USG) grants, cooperative agreements and contracts managed by CARE as the prime recipient. Under FFATA, CARE must report any subgrant greater than or equal to $30,000 and any subsequent obligation increase through the FSRS.gov website by the end of the month following the month of the subaward. Compliance Issues Identified as part of the FY2022 Audit Based on the finding in the FY21 Single Audit corrective actions were implemented in FY22. The delays identified in the FY22 Single Audit occurred in the first six months of the fiscal year, before planned FY22 corrective actions were fully implemented. Root Causes The root causes for the delay in reporting the partner organizations (i.e., subrecipients) information with whom CARE works with is as follows: ? Failure by the partner organization to timely adhere to the FFATA requirements delineated in the partner funding agreement (PFA). ? Delay in and confusion by the partner about registering the organization in SAM.gov (a USG database) and system difficulties in obtaining a Unique Entity Identifier Number (UEI), through SAM.gov. Recommended Solutions by CARE Management Team by June 30, 2023 1. Award Management Solutions (AMS) team will: a. Issue additional guidance and notification to all CARE business units involved with FFATA compliance. b. Deliver refresher training for all CARE country offices and HQ units involved with FFATA compliance. c. Complete the terms of reference and initiate the development of an award management platform for COs and HQ units to manage the donor compliance reporting and administration across the organization. 2. CARE will implement preventative controls to reduce the risk of future non-compliance, including: a. Ensure that partners are aware of SAM.gov registration at the proposal development stage; require partners to submit the completed FFATA form before full execution of the PFAs and PFA modifications; and include the completed FFATA form in the approval process. b. AMS will review the PFA templates to include partner DUNS/UEIN and assign a field for a PFA reference number. c. SSC to modify the Project ID (PID) set-up form to include a DUNS/UEIN. d. SSC will strictly enforce the submission of the FFATA collection form before setting up a new PID for USG PFAs and for PFA obligation increases. SSC will continuously monitor for compliance and notify the CARE Country Director of non-compliance instances, copying in the Regional Director (HQ Technical Director for non-CARE USA COs), VP IPO (or VP Program Strategy & Impact) the CFO and the AVP AMS. A Key Performance Indicator (KPI) on donor reporting timeliness will be included on the Country Director KPI dashboard. Repeated instances of non-compliance will be considered a personnel performance issue with the CARE Country Director or a contractual performance issue with the non-CARE USA CO. 3. SSC will monitor: (i) first tier partner funding spending against obligation under USG awards to anticipate potential modifications; (ii) USG awards spending and set-up in the system; and (iii) the completeness of USG awards and PFA documents. SSC will provide a monitoring report to AMS. AMS will spot check the report and provide a response to SSC on non-compliance issues identified and recommended corrective actions. AMS will escalate concerns on gaps identified to the CFO. Responsible Contact: ? Jason Zeno, CARE USA, AVP Grants, Contracts & Donor Compliance, email: jason.zeno@care.org