Finding Text
2022-001: First tier subawards were not reported on the Federal Funding Accountability and Transparency Act Subaward Reporting System (?FSRS?)Cluster: Not applicableFederal Granting Agency: Health Resources and Services Administration (?HRSA?)Award Name: Coordinated Services and Access to Research for Women, Infants, Children, and Youth (?Ryan White Part D Program?)Award #: 7 H12HA45378-01-00; 2 H12HA45378-02-00Assistance Listing #: 93.153Award Year: Fiscal year 2022Pass-through entity: N/ACondition:As part of PwC?s testing over the reporting requirements related to the Ryan White Part D Program, we identified a first tier subaward to Duke University in the amount of $128,218 during fiscal year 2022, and this subaward was not reported within the FSRS system, as required.Criteria:The Federal Funding Accountability and Transparency Act (?FFATA?) of 2006 requires full disclosure of all entities and organizations receiving federal funds, including grants, contracts, loans, and other assistance and payments. Prime Grant Recipients awarded a new Federal grant greater than or equal to $30,000 as of October 1, 2010 are subject to FFATA sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 27, 2010. The prime awardee is required to file a FFATA sub-award report in the FSRS system by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.Cause:Management did not perform a thorough review of the contract, which noted the FSRS reporting requirement related to subawards that was relevant to the Company and as such, they failed to file the required notification of subaward within the FSRS system for Duke University, a first tier subrecipient under the Ryan White Part D Program.Effect:The appropriate report was not filed and as such, the FSRS system did not appropriately include the first tier subaward from Novant Health to Duke University under the Ryan White Part D Program for fiscal year 2022.Recommendation:We recommend the Company implement a contract summarization control whereby the grant accountant (or designee) summarize all relevant aspects of the contract(s) for the fiscal year. This summary should then be reviewed by the grant/program coordinator prior to the start of the contract to ensure that all relevant requirements are included within the summary and to discuss with the appropriate individuals the plan to execute on each requirement.Management?s Views and Corrective Action Plan:Management?s views and corrective action plan is included at the end of this report after the summary schedule of prior audit findings and status.