Finding Text
Assistance Listing Number, Federal Agency, and Program Name: Assistance Listing Number 64.033, Department of Veteran Affairs, VA Supportive Services for Veteran Families Program
Federal Award Identification Number and Year: 21-MI-221, 22-MI-221, 20-MI-221-SS, 20-MI-221-LT, 20-MI-221
Pass-through Entity – N/A
Finding Type – Material weakness in internal control over compliance
Repeat Finding – No
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 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 requirements pertain to recipients (i.e., direct recipients) of grants or cooperative agreements who make first-tier subawards and contractors (i.e., prime contractors) that award first-tier subcontracts. Grant and cooperative agreement recipients and contractors are required to register FSRS and report subaward data through FSRS. Compliance testing of the Transparency Act reporting requirements must include the following key data elements about the first-tier subrecipients and subawards under grants and cooperative agreements.
Criteria - Grant and cooperative agreement recipients and contractors are required to register FSRS and report subaward data through FSRS. Compliance testing of the Transparency Act reporting requirements must include the following key data elements about the first-tier subrecipients and subawards under grants and cooperative agreements.
Per 2 CFR section 200.303(a), a non-Federal entity must: 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.
Condition – During our testing for reporting compliance, it was noted that the Organization did not submit the Federal Funding Accountability and Transparency Act report within the reporting timeline for prime grant recipients.
Identification of How Questioned Costs Were Computed – N/A
Questioned Costs – None
Cause/Effect – The Organization’s procedures and controls were not sufficient to ensure that subawards were reported to FSRS during FY 2023. Subawards were not reported to FSRS in accordance with FFATA requirements. The Organization was required to report the subaward details above. The Organization was not required to report executive compensation.
Recommendation – We recommend the Organization establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward.
View of Responsible Officials and Corrective Action Plan – The Agency agrees with this finding. As part of the subaward review process, the Chief Financial Officer will ensure that first tier subawards are checked to see if FFATA reporting is needed based on the award amount. If FFATA reporting is required, the Chief Financial Officer will assign this task to the Assistant Director for Financial Compliance to ensure that reporting is completed to the FFATA Reporting System FSRS.