Finding Text
Federal Agency: Department of Justice
Federal Assistance Listing Numbers: 16.756, 16.726
Programs: Court Appointed Special Advocates, Juvenile Mentoring Program
Award/Pass-Through Entity Identifying Numbers: 2018-CH-BX-K001, 15PJDP-21-GK-02762-CASA, 2019-MU-FX-0004, 2020-JU-FX-0028
Criteria: The Uniform Guidance in 2 CFR Section 200.303 requires that non-federal entities receiving federal awards (i.e., auditee management) establish and maintain internal control designed to reasonably ensure compliance with federal statues, regulations, and the terms and conditions of the federal award.
In accordance with the requirements 2 CFR §1402.300(b), a non-federal entity is responsible for complying with all requirements of the federal award. For all federal awards, this includes the provisions of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “FFATA,” that are codified in 2 CFR Part 170, which includes requirements on executive compensation, and also requirements implementing the Act for the non-federal entity at 2 CFR part 25, Financial Assistance Use of Universal Identifier and System for Award Management, and 2 CFR part 170, Reporting Subaward and Executive Compensation Information.
In accordance with 2 CFR Part 170, Appendix A, under FFATA, National CASA/GAL is required to collect and report information on each subaward or amendment of $30,000 or more in federal funds in the FFATA Subaward Reporting System (FSRS). The subawards are required to be reported no later than the last day of the month following the month in which the subaward obligation was made or modified.
Condition: During our testing of reporting, we selected 12 subrecipient awards within Court Appointed Special Advocates and 16 subrecipient awards within the Juvenile Mentoring Program that were subject to FFATA.
Within the Court Appointed Special Advocates, 10 out of 12 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For all samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions.
Within the Juvenile Mentoring Program, 14 out of 16 awards subject to FFATA submission requirements were submitted after the last day of the month following the month in which the subaward obligation or amendment was made. For seven samples tested, National CASA/GAL did not maintain the proper evidence over review or approval of the FFATA submissions.
Cause: National CASA/GAL did not follow the documented policies and procedures to ensure compliance with the FFATA filing requirements.
Effect or Potential Effect: National CASA/GAL could be exposed to a reduction or elimination of funds by the federal awarding agencies.
Questioned Costs: None.
Context: This is a condition identified based upon our review of National CASA/GAL’s compliance with specified requirements. For the Court Appointed Special Advocates Program, nine out of 12 awards subject to FFATA selected for testing were submitted within one month of the required submission date. One out of 12 awards was submitted within three months of the required submission date. For the Juvenile Mentoring Program, nine out of 16 awards subject to FFATA selected for testing were submitted within one month of the required submission date. Five out of 16 awards were submitted within one month of the required submission date. The sample was selected based on a non-statistical basis. The prevalence of these is detailed in the condition section above.
Identification as a Repeat Finding: Not a repeat finding.
Recommendation: We recommend that reports are submitted timely with proper control procedures in place to ensure compliance with 2 CFR Section 200.303.
Views of Responsible Officials: Management concurs with this finding. Management will add additional procedures to verify the appropriateness of submitted subrecipient information within their FFATA reporting packet. Management will additionally ensure FFATA reports are submitted within the required timeline.