Finding Text
Finding 2023-001, Reporting - U.S. Department of Health and Human Services, Head Start Cluster: ALN 93.600
Criteria or Specific Requirement: Under the requirements of the Federal Funding Accountability and Transparency Act ("Transparency Act") that are codified in 2 CFR Part 170, recipients (i.e. direct recipients) of grants or cooperative agreements who make a first tier subaward of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System ("FSRS") and report subaward data through FSRS. Reporting to FSRS should be no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made.
Condition: During our testing of the reporting compliance requirement, it was noted that the Organization has a subaward that will meet the requirements for FFATA reporting and has to be reported to the FSRS. The Organization did not report the subaward information timely.
Cause: Management was not aware that they have to register and report subaward information in the FSRS related to the first tier subaward given to another entity that was over $30,000.
Effect: The Organization did not comply with the reporting compliance requirement as required by the Transparency Act.
Context: During our testing, it was noted that the Organization has one first tier subaward that was not reported timely into the FSRS.
Questioned Costs: None.
Identification of Repeat Finding: Yes. See 2022-002.
Recommendation: We recommend that the Organization register in the FSRS and timely report the required subaward information as required by the Transparency Act.
Views of Responsible Official: There is a specific compliance requirement that all direct subawards with an obligated amount over $30,000 threshold must be reported as such by no later than the end of the following month of the agreement to FSRS. There was an oversight on the specifics on this requirement resulting in a late report. Going forward, workflow has been amended to take this requirement into account and to submit the report on a timely basis, no later than the end of the following month of the agreement.