Finding 35251 (2022-001)

Section II - Financial Statement Findings There were no findings related to the consolidated financial statements which are required to be reported in accordance with generally accepted government auditing standards (GAGAS). Section III - Federal Program Findings and Questioned Costs 2022-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Information on the Major Federal Program: United States Department of Housing and Urban Development Assistance Listing Number: 14.169 Assistance Listing Name: Housing Counseling Grant FY20 Grant Award Numbers under the Uniform Guidance Requirements: Direct Award Number Award Period HC200011003 October 1, 2019 through March 31, 2022 Criteria: In accordance with the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?FFATA? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In accordance with the requirements of 2 CFR Section 1402.300, the non-Federal entity is responsible for complying with all requirements of the Federal award. For all Federal awards, this includes the provisions of FFATA, which includes requirements on executive compensation, and also requirements implementing the Act for the non-Federal entity at 2 CFR part 25 Financial Assistance Use of Universal Identifier and System for Award Management and 2 CFR part 170 Reporting Subaward and Executive Compensation Information. Condition: A sample of six program subrecipients were tested and our examination of the monitoring and reporting requirements revealed that CCUSA did not report the information on one subaward of $30,000 or more in federal funds and three grant amendments in the FFATA Subaward Reporting System to fulfil the FFATA requirements. Transactions tested: 6; Suaward not reported - 4; Dollar Amount of tested transactions - $300,460; Subaward note reported: $108,307; Repot not timely - $108,307. Cause: The Organization does not have adequate policies and procedures in place to ensure compliance with the requirements regarding FFATA. Effect or Potential Effect: Failure to comply with the reporting requirements of the Uniform Guidance could result in the awarding agency taking action such as reducing future funding. Questioned Costs: None. Context: This is a condition identified based upon our review of the Organization?s compliance with specified requirements. The sample was selected on a non-statistical basis. The prevalence of these findings is detailed in the condition section above. Repeat finding: This is not a repeat finding. Recommendation: BDO recommends that the Organization immediately establish policies and procedures to ensure FFATA requirements are satisfied for subrecipients meeting the requirements. Views of Responsible Officials: CCUSA Finance team will work with the program managers on all federal grants to create policies and procedures surrounding the FFATA reporting requirements. See CCUSA?s corrective action for more detail.