Finding 524727 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-02-27
Audit: 344147
Organization: American Near East Refugee Aid (DC)
Auditor: Rsm US LLP

AI Summary

  • Core Issue: Anera failed to submit the required FFATA report for a subaward on time.
  • Impacted Requirements: This noncompliance violates the reporting obligations set by the Federal Funding Accountability and Transparency Act.
  • Recommended Follow-Up: Anera should submit the overdue report, train staff on FFATA requirements, and enhance internal controls to ensure timely reporting in the future.

Finding Text

Finding 2024-001: Noncompliance with Rules and Regulations With Regards to Reporting Requirements Under the Federal Funding Accountability and Transparency Act (FFATA) Agency and Award: U.S. Department of State, Assistance Listing Number 19.519 Overseas Refugee Assistance Program for Middle East and North Africa Program 2022 federal award SPRMCO22CA0136 Criteria: Under the requirements of FFATA (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 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. 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. There are limited exceptions as specified in 2 CFR Part 170 and the Federal Acquisition Regulation. Condition: Anera did not submit the FFATA report for the subaward within the required timeframe. Cause: The failure to submit the report was due to lack of awareness of the reporting requirements. Questioned costs: None. Effect: Anera is in non-compliance with FFATA reporting requirements. No other reporting issues noted. Repeat finding: No. Recommendation: Anera should submit the overdue FFATA report for the subaward to Americares as soon as possible, provide training to relevant staff on FFATA reporting requirements to prevent future occurrences, and implement stronger internal controls and monitoring mechanisms to ensure timely and accurate submission of all required reports. View of responsible officials of the Auditee: Anera concurs with this finding and a response is included in the corrective action plan.

Corrective Action Plan

Identifying Number: 2024-001 Finding: Noncompliance with Rules and Regulations with regards to Reporting Requirements under the Federal Funding Accountability and Transparency Act (FFATA) Corrective Actions Taken: The first step is to submit the outstanding FFATA under U.S. Department of State cooperative agreement SPRMCO22CA0136, which was completed on February 17, 2025. Moving forward, Anera will implement a centralized tracking system to ensure the timely and accurate submission of all annual and government reporting requirements, as well as reports that may be triggered based on spending. A centralized tracker will be created for all agreements under the grants and compliance team, including specific deadlines and submission dates with links to those submissions. This system will provide visibility across all departments and stakeholders, ensuring that all reporting obligations are met promptly and preventing any oversight. The tracker will be maintained and regularly updated to reflect any changes in requirements or deadlines, fostering better coordination and accountability across Anera. Additionally, in order to enhance transparency and avoid potential siloing, the grants and compliance team will be expanded to include multiple team members with clear roles and responsibilities. This expansion will ensure that there is no over-reliance on any one individual, allowing for cross-functional knowledge sharing and greater collaboration. The team will work together to review and validate all reporting requirements, ensuring a more thorough and accurate submission process moving forward. This approach will also facilitate the identification and mitigation of any potential risks early in the process, strengthening overall compliance efforts. Name of Responsible Official and Title: Shanna Todd, International Grants Director Date Corrective Action Plan Executed: 2-3 Months (This time includes the onboarding new team members, building out the trackers, cross referencing all current obligations and rolling out to wider team.)

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 524728 2024-001
    Significant Deficiency
  • 1101169 2024-001
    Significant Deficiency
  • 1101170 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
19.519 Overseas Refugee Assistance Program for Middle East and North Africa Program $1.79M