Finding Text
SIGNIFICANT DEFICIENCY 2022-02 Timely Submission of Quarterly SF-425 Report Condition: During our testing of compliance, we noted that the organization filed the quarterly SF-425 for the period ending December 31, 2021 late. The SF-425 was due January 30, 2022, and was not submitted until February 9, 2022. Criteria: Under the Uniform guidance and terms of the federal award agreement, the Organization is required to submit the quarterly SF-425 report at the end of each quarter within 30 days from the last day of the service for each program quarter. Cause: The due date of the reporting was missed by the Organization and therefore the report was not submitted timely. Effect: The quarterly SF-425 report was filed late and was not in compliance with the Uniform Guidance and the federal award requirements. Questioned Costs: None. Perspective Information: This occurrence appears to be an isolated instance. Repeat Finding: This was a repeat finding in the immediate prior audit. Since the noncompliance in FY22 occurred before the final audit report was issued, there was a repeat in the noncompliance. Recommendation: We recommend that the Organization review its monitoring process for the quarterly reporting of SF-425 reports, and ensure reports are filed timely within the requirements of the reporting deadlines. If an extension is necessary for any instances of reporting, a request for extension should be filed with the federal agency, along with a justified explanation for the additional time needed. Otherwise, all quarterly reports should be filed timely within 30 days after the end of each calendar quarter. Views of Responsible Officials and Planned Corrective Action: Move United will put in place a three-tier redundancy plan for ensuring that filings, both within the VA Salesforce system and within the Payment Management System, are filed prior to or on time each quarter. The Chief Financial Officer, Programs Director and Grants Administrator will work collaboratively to complete the necessary data compilation at least one week prior to the filing deadline. All three individuals will be trained on and have access to the two systems. In the event one individual is incapacitated at the time of filing, one of the other two will complete the filing on time. Since the FY21 audit report has been issued, in April 2022, the Organization has implemented a corrective action plan regarding timely filings of quarterly reports with a triple redundancy in place.