Finding 481109 (2022-009)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2024-08-14
Audit: 317239
Organization: National Casa Association (WA)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: National CASA/GAL failed to submit FFATA reports on time for most subawards, risking compliance with federal requirements.
  • Impacted Requirements: Non-compliance with 2 CFR §1402.300(b) and FFATA reporting timelines, which could lead to funding reductions.
  • Recommended Follow-Up: Implement stronger controls and procedures to ensure timely FFATA submissions and compliance with 2 CFR Section 200.303.

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.

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 481081 2022-002
    Significant Deficiency
  • 481082 2022-002
    Significant Deficiency
  • 481083 2022-002
    Significant Deficiency
  • 481084 2022-002
    Significant Deficiency
  • 481085 2022-003
    Material Weakness
  • 481086 2022-003
    Material Weakness
  • 481087 2022-003
    Material Weakness
  • 481088 2022-003
    Material Weakness
  • 481089 2022-004
    Material Weakness
  • 481090 2022-004
    Material Weakness
  • 481091 2022-004
    Material Weakness
  • 481092 2022-004
    Material Weakness
  • 481093 2022-005
    Significant Deficiency
  • 481094 2022-005
    Significant Deficiency
  • 481095 2022-005
    Significant Deficiency
  • 481096 2022-005
    Significant Deficiency
  • 481097 2022-006
    Significant Deficiency
  • 481098 2022-006
    Significant Deficiency
  • 481099 2022-007
    Significant Deficiency
  • 481100 2022-007
    Significant Deficiency
  • 481101 2022-007
    Significant Deficiency
  • 481102 2022-007
    Significant Deficiency
  • 481103 2022-008
    Significant Deficiency
  • 481104 2022-008
    Significant Deficiency
  • 481105 2022-008
    Significant Deficiency
  • 481106 2022-008
    Significant Deficiency
  • 481107 2022-009
    Significant Deficiency
  • 481108 2022-009
    Significant Deficiency
  • 481110 2022-009
    Significant Deficiency
  • 1057523 2022-002
    Significant Deficiency
  • 1057524 2022-002
    Significant Deficiency
  • 1057525 2022-002
    Significant Deficiency
  • 1057526 2022-002
    Significant Deficiency
  • 1057527 2022-003
    Material Weakness
  • 1057528 2022-003
    Material Weakness
  • 1057529 2022-003
    Material Weakness
  • 1057530 2022-003
    Material Weakness
  • 1057531 2022-004
    Material Weakness
  • 1057532 2022-004
    Material Weakness
  • 1057533 2022-004
    Material Weakness
  • 1057534 2022-004
    Material Weakness
  • 1057535 2022-005
    Significant Deficiency
  • 1057536 2022-005
    Significant Deficiency
  • 1057537 2022-005
    Significant Deficiency
  • 1057538 2022-005
    Significant Deficiency
  • 1057539 2022-006
    Significant Deficiency
  • 1057540 2022-006
    Significant Deficiency
  • 1057541 2022-007
    Significant Deficiency
  • 1057542 2022-007
    Significant Deficiency
  • 1057543 2022-007
    Significant Deficiency
  • 1057544 2022-007
    Significant Deficiency
  • 1057545 2022-008
    Significant Deficiency
  • 1057546 2022-008
    Significant Deficiency
  • 1057547 2022-008
    Significant Deficiency
  • 1057548 2022-008
    Significant Deficiency
  • 1057549 2022-009
    Significant Deficiency
  • 1057550 2022-009
    Significant Deficiency
  • 1057551 2022-009
    Significant Deficiency
  • 1057552 2022-009
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
16.756 Court Appointed Special Advocates $7.69M
16.726 Juvenile Mentoring Program $1.47M