Finding 477907 (2023-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-07-08
Audit: 314590
Organization: The Southeast Conference (AK)

AI Summary

  • Core Issue: SEC failed to submit timely and accurate reports for subawards, violating FFATA requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 200 and FFATA reporting standards for federal grants over $30,000.
  • Recommended Follow-Up: Implement staff training and improve internal controls to ensure accurate and timely reporting of subawards.

Finding Text

Finding # 2023-001 – Reporting Type of Finding Significant Deficiency in Internal Control and Noncompliance ALN Title Economic Development Assistance ALN 11.307 Total Federal Expenditures $761,377 Federal Award Numbers ED22HDQ3070044, 07-79-07888, 07-79-07889, 07-79-07901, 07-79-07903, 07-79-07905 Federal Award Year October 1, 2022 through September 30, 2023 Federal Agency U.S. Department of Commerce – Economic Development Administration Criteria 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart D section 200.300 and section 200.328 set forth requirements for reporting on award amounts by grantees. Southeast Conference (SEC) was awarded a direct federal grant greater than or equal to $30,000 and was therefore subject to Federal Funding Accountability and Transparency Act (FFATA) sub-award reporting requirements as outlined in the Office of Management and Budgets guidance issued August 13, 2020. As such, SEC was required to file a FFATA sub-award report by the end of the month following the month in which SEC awarded any sub-grant greater than or equal to $30,000 (Pub. L. No. 109-282 [FFATA] and Pub. L. No. 113-101 [DATA Act]). Condition and Context SEC did not submit timely or accurate reports to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for its subawards as required by FFATA guidance. Questions Costs None. Effect SEC did not comply with the reporting requirements of Uniform Guidance and FFATA. Cause SEC’s internal controls over reporting were not sufficiently designed and implemented to ensure that staff were fully knowledgeable on when and how to report subaward amounts under FFATA. Recommendation SEC should provide training to staff for preparation of financial reports and design and implement systems to accurately and timely report subawards.

Corrective Action Plan

January 8, 2024 To whom it may concern: Southeast Conference (SEC) respectfully submits the following corrective action plan for the fiscal year ending 6/30/23. Our independent single federal audit was performed by Mertz, CPA & Advisor, 3140 Nowell Ave. Juneau, AK 99801. The following finding was discovered, and a corrective plan has been implemented: Finding number: ALN Title: ALN Number: Federal Award Year: Type of Finding: 23-0001 reporting Economic Adjustment Assistance (EDA BBB) 11.307 October 1, 2022, through September 30,2023 Deficiency in Internal Control and Noncompliance Condition and Context: This was the first year that SEC needed to implement the reporting requirement to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System {FSRS) for its subawards as required by FFATA guidance. SEC did not make timely, accurate reports as required. While this did not in any way compromise federal dollars, SEC has committed to the following corrective action plan and will continue its rigorous oversight of its 13 subaward recipients. Corrective Action: SEC will review and assess all federal grant award agreements, the reporting requirements, and guidelines to follow for each. SEC has hired additional staff and delegated to them the role of reporting requirements for SEC upon completion of the assessment. Those reporting requirements include the following: • Send monthly reminders to all project managers for all new / updated contracts or sub award agreements signed to be sent out 5 days prior to the end of each month. • Compile all data received from project managers and record in tracking spreadsheets for each specific grant by the 5th of the following month. ARDOR • Send cover sheet and all contracts or sub awards signed in the previous month to SEC's Chief Financial Officer (CFO) for FFATA reporting by the 7th of every month. • Train finance staff for FFATA reporting and compliance guidelines, completed by 1/31/24. • Engage in semiannual compliance reviews with an experienced federal audit consultant. In addition to the FFATA reporting, the executive assistant will also review with the CFO all reporting requirements for all grants and contracts whether they are monthly, quarterly, semiannually, or annually. Once this review and assessment is completed, the executive assistant will develop an internal reporting calendar and execute the following: • Regular reminders based on reporting requirements to all project managers and the finance staff for all related progress and financial reporting. • Follow up with project managers and finance staff 10 days prior to the deadline to ensure all reporting has been completed. Anticipated Completion Dates: • Grant award review 1/15/24 • Development of compliance corrective action 1/20/24 • Implementation of compliance reporting 1/20/24 • Finance staff training FFATA 1/31/24 • Additional BBB finance technician training 2/05/24 Responsible individual: Robert Venables, Executive Director. SEC and their contracted CFO have discussed the corrective action plan and are working cooperatively to ensure that all deadlines are met for compliance and training. Thank you, Robert Venables Executive Director

Categories

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting Significant Deficiency

Other Findings in this Audit

  • 1054349 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
11.307 Economic Adjustment Assistance $761,377
11.302 Economic Development_support for Planning Organizations $90,335
10.890 Rural Development Cooperative Agreement Program $61,698
20.534 Fy 2022 Ost Cds - Ev Ferry Pilot Program for Southeast Conference, Alaska $21,682
90.100 Denali Commission Program $16,915
10.868 Rural Energy for America Program $14,442
10.708 Community Wood Energy and Wood Innovation Program $1,094