Finding 44418 (2022-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2023-03-29

Audit: 52407

Organization: Carole Robertson Center for Learning (IL)

Auditor: Sassetti LLC

AI Summary

Core Issue: The Center failed to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System (FSRS) and did not file the required annual Form SF-429.
Impacted Requirements: Noncompliance with the Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR Part 170, as well as failure to meet annual reporting obligations for real property.
Recommended Follow-Up: The Center should establish internal controls to ensure timely FFATA reporting and complete the SF-429 form annually, even if there is no reportable real property.

Finding Text

Finding 2022-001: Internal Control over Reporting (Significant deficiency, Compliance Finding) Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: N/A ? Direct Award Program Name: Head Start Cluster Assistance Listing Number:93.600 Award Numbers: 05CH01205802, 05HE00139001C6, 05HP00044002 Category of Finding: Reporting Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA), as codified in 2 CFR Part 170, direct recipients of grants are required to report first-tier subawards of $30,000 or more to the FFATA Subaward Reporting System (FSRS) no later than the end of the month following the month in which the subaward obligation was made. The Center is also required to file form SF-429 Real Property Status Report annually. Condition/Context: During testing of reporting compliance requirement related to Head Start, it was determined that FFATA reporting to FSRS was not done for the subgrants awarded. "See Schedule of Findings and Questionend Costs for chart/table". Additionally, the Form SF-429 Real Property Status Report is required to be filed annually with the SF-425. The Center does not have any reportable real property, but instructions require that the form be completed regardless. Cause: The Center?s internal controls did not detect that FFATA and Form SF-429 reporting was required and not been performed. Effect: Failure to submit the required FFATA reports by the end of the month following an award given to a subrecipient results in noncompliance with 2CFR Part 170. Failure to submit annual SF-429 report results in noncompliance with requirements. Questioned costs: None Repeat Finding: No Recommendation: The Center should evaluate each award for applicability of FFATA and Form SF-429 reporting and develop processes and internal controls to ensure proper submission of reports by the end of the month following an award given to a subrecipient in the case of FFATA reporting, and ensure the SF-429 is filed when the Form SF-425 is submitted. Management?s response: Management agrees with this finding. Please see corrective action plan.

Corrective Action Plan

Finding 2022-001: Failure to submit the required Federal Funding Accountability and Transparency Act (FFATA) report by the end of the month following an award to a subrecipient results in noncompliance with 2CFR Part 170. Failure to submit annual SF-429 report results in noncompliance with requirements. Corrective Actions Taken or Planned: Management concurs with this finding. This is a new requirement for Carole Robertson Center for Learning related to its Head Start/Early Head Start grant. As a recent Office of Head Start grantee, we were unaware of this reporting requirement. We have amended our internal controls to add the FFATA report and the SF-429 report on December 31 each year in our newly created Finance Department Compliance Calendar. Further, we have pursued additional trainings and resources for new Head Start grantees to ensure compliance with reporting requirements. In addition, a system of oversight and monitoring of the Compliance Calendar will be established to provide an additional layer of review for these reports. Implementation is planned for completion by April 30th, 2023. The contact person is Peg Heslinga, Chief Financial Officer.

Other Findings in this Audit

44419 2022-002

Significant Deficiency
620860 2022-001

Significant Deficiency
620861 2022-002

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
93.600	Head Start	$243,021
10.558	Child and Adult Care Food Program	$159,578
84.287	Twenty-First Century Community Learning Centers	$144,402
93.558	Temporary Assistance for Needy Families	$81,363
21.019	Coronavirus Relief Fund	$13,904