Finding 42474 (2022-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-06-28

AI Summary

  • Core Issue: The Fund failed to report subaward data accurately and on time as required by the Federal Funding Accountability and Transparency Act (FFATA).
  • Impacted Requirements: Recipients must report first-tier subawards of $30,000 or more and maintain registration in the System for Award Management (SAM) and FSRS.
  • Recommended Follow-Up: Implement a review process where a different person checks FFATA reports for accuracy before submission.

Finding Text

Finding 2021?002: Reporting Finding Type: Noncompliance, Significant Deficiency Federal Department: U.S. Department of Health and Human Services FAIN: NH75OT000036 COVID-19 ? Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crisis, Federal Assistance Listing Number 93.391 Criteria: Federal Funding Accountability and Transparency Act Aspects of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act), as amended by Section 6202 of Pub. L. No. 110-252, that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). The requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. There are limited exceptions as specified in 2 CFR Part 170 and the FAR. The guidance at 2 CFR Part 170 currently applies only to federal financial assistance awards in the form of grants and cooperative agreements (e.g., it does not apply to loans made by a federal agency to a recipient), however the subaward reporting requirement applies to all types of first-tier subawards under a grant or cooperative agreement. Direct recipients are required to report each first-tier subaward or subaward amendment that results in an obligation of $30,000 or more in federal funds. Prime contractors are required to report each first-tier subcontract award of $30,000 or more in federal funds. Grant and cooperative agreement recipients and contractors are required to register in FSRS and report subaward data through FSRS. To do so, they will first be required to register in the System for Award Management (SAM) (if they have not done so previously for another purpose (e.g., submission of applications through Grants.gov) and actively maintain that registration. Prime contractors have previously been required to register in SAM. Information input to FSRS is available at USASpending.gov as the publicly available website for viewing this information (https://www.usaspending.gov/search). Condition: The Fund has an obligation to report subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA). This includes subawardee information, subawardee DUNS or SAM number or Unique Entity ID, and relevant executive compensation, if applicable. Based on our selection of eight subawards for testing, the following was noted. See Schedule of Findings and Questioned Costs for chart/table. Cause: Due to the large volume of COVID-19 work during fiscal year 2022 and understaffing for the Grants and Contracts team, the Fund did not consistently have personnel in place to ensure they submitted subaward information in FFATA reports accurately and timely. Effect: The Fund did not submit subaward information in certain FFATA reports accurately or timely. Questioned Costs: None Recommendation: We recommend that the Fund implement internal control procedures whereby someone other than the preparer reviews the FFATA reports to ensure accurate and timely reporting of all required subawards on FFATA reports prior to submission. View of Responsible Officials: Management agrees with the recommendation. The Organization?s corrective action plan is on page 43 of the audited financial statements report.

Corrective Action Plan

Finding 2022?002 Reporting Corrective Action Plan: To ensure timely and accurate reporting of subaward data as required under the Federal Funding Accountability and Transparency Act (FFATA), the Fund will update its internal procedures to enhance tracking and monitoring. This will include requiring that the FFATA reports are prepared and then reviewed by the preparer?s supervisor prior to submission. The Fund will also ensure that appropriate staff are notified and trained on the requirements and updated process. Management will monitor this issue regularly during the year to ensure compliance. Person Responsible for Correction Action: Rebecca Adeskavitz, Chief Operating Officer Projected Date of Completion: This corrective action plan will be implemented immediately in response to the Auditor?s recommendation.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 618916 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.268 Covid-19 - Immunization Cooperative Agreements $24.60M
97.036 Covid-19 - Disaster Grants - Public Assistance (presidentially Declared Disasters) $21.27M
93.323 Covid-19 - Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $16.78M
93.391 Covid-19 - Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $11.04M
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $3.15M
93.914 Hiv Emergency Relief Project Grants $2.26M
93.136 Injury Prevention and Control Research and State and Community Based Programs $1.99M
10.331 Food Insecurity Nutrition Incentive Grants Program $1.93M
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $1.69M
93.297 Teenage Pregnancy Prevention Program $1.42M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $974,670
93.926 Healthy Start Initiative $875,086
93.226 Research on Healthcare Costs, Quality and Outcomes $341,253
93.116 Project Grants and Cooperative Agreements for Tuberculosis Control Programs $315,948
14.241 Housing Opportunities for Persons with Aids $253,282
93.070 Environmental Public Health and Emergency Response $195,783
93.082 Sodium Reduction in Communities $170,749
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $163,057
93.944 Human Immunodeficiency Virus (hiv)/acquired Immunodeficiency Virus Syndrome (aids) Surveillance $131,051
93.137 Covid-19 - Community Programs to Improve Minority Health Grant Program $107,601
93.478 Preventing Maternal Deaths: Supporting Maternal Mortality Review Committees (b) $78,554
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $36,261
93.137 Community Programs to Improve Minority Health Grant Program $12,458
93.350 National Center for Advancing Translational Sciences $9,665