Finding Text
AL#: 14.241
Housing Opportunities for Persons with AIDS Grant Program
Award Year: 2023
Criteria: Under the requirements 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 “FFATA” 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 subawards are required to be reported in FSRS no later than the last day of the month
following the month in which the subaward/subaward amendment obligation was made or the subcontract
award/subcontract modification was made. Applicable subaward obligations/modifications are required to be
reported.
Condition: FFATA reporting was due no later than March 31, 2023, (for the Charleston County Human Services
Commission Subaward) and no later than April 30, 2023, (Pastors Subaward). These two (2) reports were
ultimately submitted by the City in June of 2023. The FFATA reporting for the Pastors Subaward did not include a
$10,000 contract amendment, this was corrected by amending the report.
Context: We addressed the matter with City management who are aware of the reporting requirements.
Effect: Failure to properly review and adhere to policies and procedures related to reporting can lead to
noncompliance as well as the withholding of future awards and funds drawdowns by the awarding agency.
Cause: Management oversight.
Recommendation: We recommend the City review and update its policies and procedures to ensure all required
reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct
amounts.