Finding Text
2023-005. FINDING (Failure to File Real Property Status Report)
Federal Department: U.S. Department of Health and Human Services
Assistance Listing Number: 93.600
Cluster Name: Head Start Cluster
Program Name: Early Head Start
Award Numbers: 05CH011351-03-02, 05CH011351-04-03
Questioned Cost: None
Program Expenditures: $985,732
Cluster Expenditures: $1,026,985
Governors State University (University) failed to submit the required annual real property status report (SF-429).
During our audit, we identified the University did not submit the calendar year 2022 SF-429 report. The SF-429 report must be submitted by all grantees on the same date the grantee’s SF- 425 Final Federal Financial Report for the budget period is due.
Grantees must act in compliance with the requirements of this grant and applicable federal statutes, regulations, and policies as included in the Compendium of Program Instructions and Information Memoranda. The Office of Head Start has issued Program Instruction Log Number ACF-PI-HS-17-03 which requires all grantees, including those with no covered real property, to prepare and submit SF-429 with Attachment A on an annual basis at the same time as their annual SF-425 Federal Financial Report. The Program Instruction Log Number ACF-PI-HS-17- 03 is required in accordance with the Code of Federal Regulations (Code) (45 CFR 75.343).
The Code (45 CFR 75.343) requires nonfederal entities to submit reports periodically dependent on time frame on the status of real property in which the federal government retains an interest.
Additionally, the Code (2 CFR 200.303) requires nonfederal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely.
University officials stated the SF-429 report was inadvertently not submitted as there was no real property acquired from the grant funds.
Failure to meet grant reporting requirements is a noncompliance with the related grant request for proposal and application agreement and could result in loss of grant funding in future years. (Finding Code No. 2023-005)
RECOMMENDATION
We recommend the University improve its procedures to ensure timely submission of required reports.
UNIVERSITY RESPONSE
The University agrees with this finding and accepts the recommendation. Existing procedures are already in place to ensure that required reports are submitted. As indicated in the finding above, this was just a misunderstanding on the part of the employee submitting the report as there was no real property acquired from the Early Head Start grant funds. The University believes that this matter did not have a direct and material effect on the University’s compliance with federal requirements.