Finding Text
Criteria: In accordance with 2 CFR §170, prime awardees awarded a federal grant are required to file a Federal Funding Accountability and Transparency Act (FFATA) sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. Further, the Organization is subject to reporting requirements for both financial and progress reporting. In accordance with 2 CFR §200.328, Federal Financial Reports (FFR) should be submitted based on frequency required by the terms and conditions.
In instances were the Organization is a subrecipient, the grant agreement with the prime recipient Rural Community Assistance Partnership (RCAP), requires that in order to facilitate RCAP’s financial reporting requirements, the Organization is required to submit reimbursement request monthly within 10 days of the following month. Additionally, in accordance with the agreement with RCAP, in order to facilitate RCAP’s progress reporting requirements the Organization is required to submit data related to progress made within 12 days for quarterly reports under program 66.446 and a final narrative within 75 days from project close. The requirements for progress reports for program 10.761 are to be submitted within 15 days for quarterly reports and 45 days for final narrative.
Condition: During the review of the reporting compliance requirement related to major program, it was determined that a FFATA reports were not filed by the Organization within the required period. Further, the Organization did not file a FFR report within the required deadline for a grant it is a prime recipient. For grants on which the Organization is a subrecipient, it was determined that reimbursement requests and progress reports were not submitted within the required deadline.
Cause: Internal controls over financial reporting were not operating effectively to file the FFATA report a timely manner. Management was not aware of the FFATA requirements for prime awards. Further, internal controls over financial reporting were not operating effectively to file FFRs, reimbursement requests and progress reports in a timely manner.
Effect: Failure to submit the FFATA reports by the end of the following month after sub-grant greater than $30,000 is awarded results in noncompliance with 2 CFR §170. Failure to submit the semi-annual FFR within the 30-day submission deadline results in noncompliance with 2 CFR §200.328. Additionally, failure to submit the reimbursement request and progress reports within the specified deadline results in a breach of contract with RCAP.
Questioned Costs: Questioned costs were not identified.Perspective information: It is noted that the Organization has not established policies and procedures that will ensure that FFATA reports are submitted within the required timeline and therefore three out of three samples tested for this compliance requirement were not completed. Further, for the awards that the Organization was a prime recipient one out one sample tested from a population of two was submitted timely. For awards which the Organization is a subrecipient, three out of the nine samples tested from a population of thirty-six were not submitted within the specified timeline. Additionally, for awards which the Organization is a subrecipient, one out of two samples from a population of 12 were not submitted with the specified timeline. Non-compliance surrounding reporting was identified for the following awards during the fiscal 2023:
Federal Agency Pass-Through Entity ALN Federal Award Name Award Year
Department of Health and Human Services Direct 93.570 HHS RCD - SERCAP 9/30/2022 – 8/31/2023
United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Technitrain 2022-2023 9/1/2022 – 8/31/2023
United States Department of Agriculture Rural Community Assistance Partnership Inc. 10.761 Tribal 2022 - 2023 9/1/2022 – 8/31/2023
Environmental Protection Agency Rural Community Assistance Partnership Inc. 66.446 Training and Technical Assistance for Treatment Works 4/1/2022 – 9/30/2023
Repeat Finding: No similar finding was reported in the prior year.
Recommendations: We recommend that management attend training related to federal grant requirements. We also recommend that management establish procedures to ensure that it meets FFATA requirements on a timely basis. The Organization should review its internal controls surrounding financial and progress reporting for each federal award and develop an effective reporting tracking system to allow the Organization to monitor and ensure reports are prepared and submitted within deadlines.