Finding 2022-002 Noncompliance with the Uniform Guidance Compliance Requirement Reporting Federal Programs: Assistance Listing No. Name of Federal Program or Cluster 66.039 National Clean Diesel Funding Assistance Program Criteria: FFATA requires subawards in excess of $30,000 to be reported to FSRS no later than the end of the month following the month the subaward was made. Condition: MARAMA made two subawards exceeding $30,000 during fiscal year 2022 and did not report either subaward to FSRS. Context: Noncompliance was noted as a result of substantive tests of compliance whereby report submissions to FSRS are viewed. Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements 2 2 0 n/a n/a Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements $82,842 $82,842 $0 n/a n/a Cause: Reports to FSRS were not submitted because the determination of which subawards were subject to FFATA reporting was misinterpreted as the payment of federal award funds to subawardees rather than the execution of the subaward. Effect or Potential Effect: MARAMA is not in compliance with the FFATA reporting requirements. Questioned costs: Known and likely questioned costs did not exceed $25,000 and, therefore, were not required to be reported. Recommendation: MARAMA should develop procedures to ensure subawards are reported to FSRS by the reporting deadline. Subaward relationships should be re-evaluated as the agreements expire to ensure that the continued classification of the agreements as subawards is appropriate. Responsible Official?s Response: Contact Person: Marc A.R. Cone, Executive Director, 443-322-0319 MARAMA appreciates the auditor bringing the FSRS reporting requirement to MARAMA?s attention. As MARAMA and the auditor have noted, there is room for practical interpretation that could cause differing opinions on determining the business relationship of a contractor versus a subawardee. In the future, MARAMA will more closely analyze the business relationship to identify a subawardee versus contractor and, if the the business relationship with an entity is identified as a subawardee, then the FSRS reporting will be performed within the specified timeframes. Anticipated Completion Date: MARAMA anticipates that the FSRS reports for subawards entered into after July 2023 will be completely timely. Planned Corrective Action: The new accounting services provider is familiar with the nuances of analyzing the applicability of FSRS reporting. With this expertise there will be a priority to develop a plan to more closely monitor the FSRS reporting requirements.