Finding Text
Finding 2023-002 - Reporting: Federal Funding Accountability and Transparency Act ("FFATA") – Significant Deficiency
Name of Federal Agency: U.S. Department of Health and Human Services
Federal Program Name(s): Health Center Program Cluster - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and COVID-19 - Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care and Grants for New and Expanded Services Under the Health Center Program and COVID-19 - Grants for New and Expanded Services Under the Health Center Program
Assistance Listing Numbers: 93.224 and 93.527
Federal Award Identification Number(s) and Year(s): H8F4083 - 2021, H8000626 - 2022, H8G48366 - 2022
Criteria
1. In accordance with 2 CFR Section 200.303, Internal controls, the non-Federal entity must: (a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
2. Under the requirements of the FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, that are codified in 2 CFR Part 170, prime 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 prime recipient is required to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000.
Condition
1. During our audit, we noted there was no evidence of review and approval by someone other than the preparer of the FFATA subawards that were submitted to the FSRS.
2. During our audit, we noted the FFATA subawards were not submitted timely to the FSRS.
Transactions
Tested Subaward not
reported Report not
timely Subaward amount
incorrect Subaward missing key elements
4 4 4 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$6,845,844 $6,845,844 $6,845,844 $0 $0
Cause
1. There is no formal policy in place requiring the CFO (or designee) to review and approve the FFATA reports before submission to the FSRS.
2. As a result of personnel changes within the finance department, the FFATA reporting was not done timely.
Effect or Potential Effect
1. The condition could result in key data elements inaccurately reported and/or not supported by the source documentation.
2. The FFATA subawards were not submitted timely to the FSRS.
Questioned Costs
None.
Context
Four exceptions from a statistically valid sample of four.
Identification as Repeat Finding
1. No
2. Yes (see prior year finding number 2022-001)
Recommendation
1. We recommend that all FFATA reports be reviewed and approved by the CFO or designee and evidence of approval be maintained.
2. We recommend that management create an e-mail reminder or other alert mechanism and implement controls to ensure compliance with the reporting requirements under FFATA.
Views of Responsible Officials
As of September 1, 2023, BCHN implemented a workflow where FFATA information will be reported to the FSRS upon receipt of the Notices of Award. In addition, as of September 9, 2024, the FFATA report will be reviewed by someone other than the preparer prior to submission and evidence of the approval maintained.