FAC Explorer

Finding 403584 (2023-001)

Significant Deficiency Repeat Finding
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-06-27
Audit: 310612
Organization: Family Health International (NC)
Auditor: Ernst & Young LLP

AI Summary

  • Core Issue: FHI 360 failed to report accurate information and submit required FFATA reports for first-tier subawards of $30,000 or more, leading to non-compliance with federal requirements.
  • Impacted Requirements: Compliance with 2 CFR Section 200.303 and 2 CFR Part 170 regarding internal controls and timely reporting of subawards.
  • Recommended Follow-Up: Strengthen internal controls and procedures for FFATA reporting, including enhanced training and centralized review processes to ensure timely and accurate submissions.

Finding Text

Finding 2023-001 – Reporting – Federal Funding Accountability and Transparency Act (FFATA) Identification of the federal program: Federal Agency: United States Agency for International Development Assistance Listing: 98.001 – USAID Foreign Assistance for Programs Overseas 98.U04 – USAID Foreign Assistance for Economic Growth Federal Award Identification Number 98.001 – 7200AA19CA00002; 72066418CA00001; 72044020CA00002; 72049218CA00008; 72060822CA00002; 72066322CA00005 98.U04 – 72026320C00005 Award Year: FY 2022 – 2023 Criteria or specific requirement (including statutory, regulatory or other citation): 2 CFR Section 200.303 of the Uniform Guidance states the following regarding internal control: “The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”Family Health International Schedule of Findings and Questioned Costs (continued) Year Ended September 30, 2023 2311-4384437 80 Section III – Federal Award Findings and Questioned Costs (continued) As per 2 CFR Part 170, 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 subaward information should be reported no later than the end of the month following the month in which the obligation was made. Condition: We noted the following matters during our testing of the Federal Funding Accountability and Transparency Act (FFATA) reporting compliance requirements: See chart/table in the schedule of findings and questioned costs Cause: A thorough review of the required data elements prior to submission of the reports did not occur consistently in FY 2023. In addition, a detailed review of all new subaward agreements and/or modifications made during FY 2023 was not performed to identify reports that should have been submitted. Effect or Potential Effect: FHI 360 did not report accurate information or did not submit the required reports for first-tier subawards of $30,000 or more causing them not to be in compliance with federal reporting requirements. Questioned Costs: NoneFamily Health International Schedule of Findings and Questioned Costs (continued) Year Ended September 30, 2023 2311-4384437 82 Section III – Federal Award Findings and Questioned Costs (continued) Context: Under the Transparency Act reporting requirements, each FFATA report includes the following key data elements: 1) Subawardee name, 2) Subawardee DUNS #, 3) Amount of Subaward, 4) Subaward Obligation/Action Date, 5) Subaward Number, 6) Subaward Project Description, 7) Subawardee Names and Compensation of Highly Compensated Officers, if thresholds are met and 8) Date of Report Submission. Testing of the FFATA reports included each of these data elements as well as verifying for timely submissions. The table presented above lists the specific data elements where errors were detected as well as any untimely or non-submission of the reports. Total federal expenditures under 98.001 and 98.U04 were $ 509,476,610 and $3,502,691, respectively, for the year ended September 30, 2023. Identification as a Repeat Finding: This is a repeat finding from prior year (2022-001). Recommendation: We recommend FHI 360 strengthen its internal controls and procedures over FFATA reporting to ensure they are both timely and accurately submitted to be in compliance with the federal reporting requirements. Views of Responsible Officials: Management will implement additional actions to enhance and strengthen previous year actions including global communications and meetings with key management teams, targeted and detailed refresher training on FFATA requirements and completion of the FSRS template via an e-module, and additional review of FFATA submissions via a centralized team to identify prospective transactions and perform a final review of data quality prior to data entry in FSRS. The additional review will focus on completeness and accuracy of submitted data and timeliness of submissions. Management notes there were prior year FFATA findings related to timeliness of submissions which EY concluded upon in May 2023, during the current fiscal period. The corrective action plan in response to the prior year findings was immediately developed and implemented. This fiscal year’s control exceptions related to timeliness were prior to the material findings being concluded upon and the corrective action plan being implemented

Categories

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 403578 2023-001
    Significant Deficiency Repeat
  • 403579 2023-001
    Significant Deficiency Repeat
  • 403580 2023-002
    Significant Deficiency
  • 403581 2023-002
    Significant Deficiency
  • 403582 2023-001
    Significant Deficiency Repeat
  • 403583 2023-001
    Significant Deficiency Repeat
  • 403585 2023-001
    Significant Deficiency Repeat
  • 403586 2023-001
    Significant Deficiency Repeat
  • 403587 2023-001
    Significant Deficiency Repeat
  • 980020 2023-001
    Significant Deficiency Repeat
  • 980021 2023-001
    Significant Deficiency Repeat
  • 980022 2023-002
    Significant Deficiency
  • 980023 2023-002
    Significant Deficiency
  • 980024 2023-001
    Significant Deficiency Repeat
  • 980025 2023-001
    Significant Deficiency Repeat
  • 980026 2023-001
    Significant Deficiency Repeat
  • 980027 2023-001
    Significant Deficiency Repeat
  • 980028 2023-001
    Significant Deficiency Repeat
  • 980029 2023-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
98.U04 United States Agency for International Development Foreign Assistance for Economic Growth $3.50M
93.855 Allergy and Infectious Diseases Research $1.72M
17.270 Reentry Employment Opportunities $1.16M
93.600 Head Start $924,722
19.221 Regional Democracy Program $796,388
93.U03 National Health Initiatives, Strategies and Action Plans for Chronic Disease $764,751
42.U10 2020 Open World Program $735,563
85.U10 Millenium Challenge Corporation $694,669
19.345 International Programs to Support Democracy, Human Rights and Labor $617,968
93.855 Allergy and Infectious Diseases Research $541,803
98.007 Food for Peace Development Assistance Program (dap) $391,303
93.067 Global Aids $371,736
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health $356,652
19.501 Public Diplomacy Programs for Afghanistan and Pakistan $355,360
98.U08 United States Agency for International Development Foreign Assistance for Health Programs Overseas $315,839
19.301 The Secretary's Office of the Global Partnership Initiative (s/gpi) Grant Programs $275,968
93.941 Hiv Demonstration, Research, Public and Professional Education Projects $150,214
19.009 Academic Exchange Programs - Undergraduate Programs $136,661
93.865 Child Health and Human Development Extramural Research $131,717
19.432 Academic Exchange Programs - Educational Advising and Student Services $120,435
98.001 Usaid Foreign Assistance for Programs Overseas $119,534
16.812 Second Chance Act Reentry Initiative $111,446
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $106,965
84.048 21st Century Act - Michigan Department of Education $74,467
19.021 Investing in People in the Middle East and North Africa $70,490
10.608 Food for Education $60,016
19.415 Professional and Cultural Exchange Programs - Citizen Exchanges $49,910
19.500 Middle East Partnership Initiative $41,052
93.137 Community Programs to Improve Minority Health Grant Program $35,248
16.815 Tribal Civil and Criminal Legal Assistance Grants, Training and Technical Assistance $34,246
93.001 Health Marketing Communic $33,581
84.U10 Fsu Gear Up Yr3 – Fayetteville State University $30,832
19.900 Aeeca/esf Pd Programs $27,620
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $26,887
98.U07 United States Agency for International Development Foreign Assistance for Education and Social Services Programs Overseas $24,500
93.279 Drug Abuse and Addiction Research Programs $16,102
47.076 Stem Education (formerly Education and Human Resources) $12,633
19.517 Overseas Refugee Assistance Programs for Africa $7,185
19.421 Academic Exchange Programs - English Language Programs $6,804
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $3,282
93.RD1 Tams Finance Cntr Liberia $2,321
19.029 The U.s. President's Emergency Plan for Aids Relief Programs $1,915
93.242 Mental Health Research Grants $1,896
19.408 Academic Exchange Programs - Teachers $1,579
12.420 Military Medical Research and Development $337
93.936 National Institutes of Health Acquired Immunodeficiency Syndrome Research Loan Repayment Program $231
19.U10 Zero to Three National Center for Infants, Toddlers & Families $190
93.U01 Training and Technical Assistance Network Program $178
19.040 Public Diplomacy Programs $128
84.326 Special Education Technical Assistance and Dissemination to Improve Services and Results for Children with Disabilities $78
93.307 Minority Health and Health Disparities Research $64
98.U10 United States Agency for International Development Foreign Assistance for Health Programs Overseas $47
10.001 Agricultural Research Basic and Applied Research $42
19.402 Professional and Cultural Exchange Programs - International Visitor Leadership Program $1
93.U02 National Health Initiatives, Strategies and Action Plans for Infectious Disease $0
84.048 Perkins Group Program - Michigan Department of Education $-6
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $-29
98.U02 United States Agency for International Development Foreign Assistance for Democracy, Human Rights Governance and Security Programs Overseas $-44
93.136 Injury Prevention and Control Research and State and Community Based Programs $-44
98.U06 United States Agency for International Development Foreign Assistance for Education and Social Services Programs Overseas $-108
93.U10 Centers for Disease Control and Prevention $-156
19.600 Bureau of Near Eastern Affairs $-455
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $-536
93.978 Sexually Transmitted Diseases (std) Provider Education Grants $-1,946
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $-5,156
12.350 Department of Defense Hiv/aids Prevention Program $-114,219