Finding 396482 (2023-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-05-13
Audit: 306096
Organization: Reinvestment Fund, Inc. (PA)
Auditor: Cohnreznick LLP

AI Summary

  • Core Issue: Reinvestment Fund, Inc. failed to report 98 subawards over $30,000 as required by FFATA.
  • Impacted Requirements: Internal controls for FFATA reporting were inadequate, leading to untimely and inaccurate submissions.
  • Recommended Follow-Up: Implement policies for FFATA compliance, maintain documentation, and train staff on reporting requirements.

Finding Text

Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 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). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified. Condition: We were unable to determine if internal controls were in place during 2023 to ensure FFATA reporting was performed, and subawards entered into by Reinvestment Fund, Inc. over $30,000 were not reported. Cause The Organization’s federal grant compliance controls did not address the general administrative controls over ensuring FFATA reporting is performed as required. Effect or Potential Effect: FFATA reporting was not performed timely and accurately. Questioned Costs: None Context: Reinvestment Fund, Inc. had 98 subawards that met the FFATA requirements which were not reported. The federal award identification numbers (FAIN) for the awards is pending from the USDA and is required to complete the FFATA reporting. Identification as a Repeat Finding: No Recommendation: We recommend that Reinvestment Fund, Inc. implement policies and procedures to review FFATA reporting and maintain documentation of internal controls as well as provide training to staff on FFATA reporting requirements. Views of Responsible Officials: The Organization acknowledges that we should have been filing information for all of our grantees over $30,000 on the FFATA Sub-award Reporting System website. We have a remediation plan in place to ensure that all past grantees over $30,000 are registered on the website, and we have included FFATA registration as a step in the creation of all future HFFI grantees.

Corrective Action Plan

Planned Corrective Action: We have a remediation plan in place to ensure that all past grantees over $30,000 are registered on the website. We are currently waiting to receive the correct FAIN numbers from the United States Department of Agriculture (USDA) for all our awards so we can file the reports correctly. Once this information is received from the USDA we are ready to submit the required reporting. We have begun reporting for the few FAIN numbers we have that seem to be correct. We have also included FFATA registration as a step in our grants compliance process for the creation of all future HFFI grantees to prevent this finding from re-occurring. Completion date: May 2, 2024 Name of Contact Person: Sara Vernon Sterman, Chief Program Officer

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 396483 2023-001
    Significant Deficiency
  • 396484 2023-001
    Significant Deficiency
  • 396485 2023-001
    Significant Deficiency
  • 972924 2023-001
    Significant Deficiency
  • 972925 2023-001
    Significant Deficiency
  • 972926 2023-001
    Significant Deficiency
  • 972927 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.014 Community Development Financial Institutions Bond Guarantee Program $67.19M
84.354 Credit Enhancement for Charter School Facilities $2.18M
21.020 Community Development Financial Institutions Program $497,059
21.011 Capital Magnet Fund $256,000
10.872 Healthy Food Financing Initiative (b) $106,048
21.027 Coronavirus State and Local Fiscal Recovery Funds $94,000
81.041 State Energy Program $62,896