2023-001: Reporting (Significant Deficiency) and Compliance
During our audit of the reporting requirements for the Organization’s subawards, we noted the Organization did not complete the necessary reporting to be in compliance with FFATA. Under the requirements of the Federal Funding Accountability and Transparency Act (“FFATA”) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The finding appears to be the result of an oversight and lack of understanding of FFATA reporting requirements.
Recommendation: We recommend the Organization implement policies and procedures to ensure its compliance with the reporting requirements of FFATA.
View of Responsible Officials:
OPCS agrees with the finding and are in the process of up-dating our procedures to mitigate issues in the future. See our Corrective Action Plan for the fiscal year ended December 31, 2023 for additional detail.
Corrective Action Plan: The finding relates to a sub-recipient in excess of $30,000 which has attached FFATA reporting requirements. Our plan to mitigate the irsk of a repeat finding Old Pueblo will implement a control where all sub-recipients more than $30,000 will undergo an additional layer of review specifically for FFATA requirements. If the associated direct award agreemenet is not clear on the requirement’s applicability management will reach out to the awarding federal agency. Sub-recipients in excess of $30,000 will have documentation that the above review was taken place by Ellyn, Langer, CFO. The new control will be in place by August 2024.