Finding 374479 (2023-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-03-08
Audit: 294142
Auditor: Marcum LLP

AI Summary

  • Core Issue: BDCC failed to report first-tier subawards of $30,000 or more as required by the Transparency Act.
  • Impacted Requirements: Compliance with the Federal Funding Accountability and Transparency Act, specifically 2 CFR Part 170.
  • Recommended Follow-Up: BDCC should establish procedures to ensure timely reporting of subawards to the FSRS.

Finding Text

Improve Controls and Timing of Reporting Federal Program Information Federal Agency: U.S. Department of Labor Cluster/Program: Community Project Funding/Congressionally Directed Spending Award Name: A Pathway to Employment for Every Working Vermonter (PEEWV) AL Number: 17.289 Award Year: 2023 Compliance Requirement: Reporting Type of Finding Compliance Internal Control over Compliance - Significant Deficiency Criteria or Specific Requirement Under 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 “Transparency Act” 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). Condition and Context BDCC did not comply with the requirements of the Transparency Act related to reporting first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS), as follows: SEE TABLE Cause Weakness in the design and operation of controls over compliance related to Transparency Act requirements. Effect or Potential Effect Due to the weaknesses in internal controls noted above, BDCC did not timely comply with the requirements of the Transparency Act related to reporting first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Questioned Costs No questioned costs are reported as this requirement is procedural in nature. Recommendation BDCC should develop procedures to comply with the Transparency Act related to reporting first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Views of Responsible Official Management agrees with the finding. Planned Corrective Action Management’s corrective action plan is included at the end of this report after the Schedule of Prior Year Findings.

Corrective Action Plan

Audit Finding Reference: 2023-001 Improve Controls and Timing of Reporting Planned Corrective Action: The Organization currently has written Grant Management Policies, and Management agrees with this finding, that these policies do not adequately address the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252 which requires recipients (i.e., direct recipients) of grants or cooperative agreements to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The Organization will update its Grant Management Policies to address the requirements of the Federal Funding Accountability and Transparency Act, and once formally adopted, the Organization will distribute the new policies and procedures to necessary staff, as well as advise and train its staff on following such policies and procedures. Planned Implementation Date of Corrective Action: June 30, 2024 Person Responsible for Corrective Action: Director of Finance & Grant Management

Categories

Reporting Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 950921 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
14.228 Community Development Block Grants/state's Program and Non-Entitlement Grants in Hawaii $358,110
17.289 Community Project Funding/congressionally Directed Spending $258,558
59.046 Microloan Program $201,759
59.007 7(j) Technical Assistance $155,656
10.870 Rural Microentrepreneur Assistance Program $126,667
11.024 Build to Scale $91,961
10.446 Rural Community Development Initiative $84,252
10.766 Community Facilities Loans and Grants $50,227
93.566 Refugee and Entrant Assistance_state Administered Programs $27,925
90.601 Northern Border Regional Development $10,000