FAC Explorer

Finding 560216 (2024-001)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-05-13
Audit: 356152
Organization: International Rescue Committee, Inc. (NY)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: Timely submission of subaward reports was not achieved for multiple agreements, violating federal reporting requirements.
  • Impacted Requirements: Non-compliance with the Federal Funding Accountability and Transparency Act (FFATA) and internal control standards, affecting transparency and accountability.
  • Recommended Follow-up: Implement stronger internal controls and staff training to ensure timely reporting and resolve access issues with SAM.gov.

Finding Text

U.S. Department of State: Bureau of Population and Refugees and Migration: Oversees Refugee Assistance Programs for Africa: Advancing access to integrated life-saving assistance and protection services to promote selfreliance and resilience for refugees and host communities in Uganda (ALN 19.517, award number SPRMCO23CA0106) U.S. Agency for International Development: USAID Foreign Assistance for Programs Oversees: Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives (ALN 98.001, award number 720BHA22GR00304) Statistically valid sample: No, and it was not intended to be. Repeat finding: Not a repeat finding. Finding Type: Noncompliance and Significant Deficiency Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, (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). Aspects of the Transparency Act that relate to subaward reporting (1) under grants and cooperative agreements were implemented in OMB in 2 CFR Part 170 and (2) under contracts, by the regulatory agencies responsible for the Federal Acquisition Regulation (FAR at 5 FR 39414 et seq., July 8, 2010). 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. Title 45 U.S. Code of Federal Regulations Part 75 (45 CFR 75), Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards for HHS Awards, section 75.2 defines Subaward as an award provided by a pass-through entity to a subrecipient for the subrecipient to carry out part of a federal award received by the pass-through entity. It does not include payments to a contractor or payments to an individual that is a beneficiary of a federal program. A subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. Further, 45 CFR 75.2 defines Subrecipient as a non-federal entity that receives a subaward from a passthrough entity to carry out part of a federal award; but does not include an individual that is a beneficiary of such award. A subrecipient may also be a recipient of other federal awards directly from a federal awarding agency. Additionally, per 2 CFR 200.303, non-federal entities must establish and maintain effective internal control over federal awards that provide 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. The following subaward data elements to be reported include the following: • Subawardee Name • Subawardee Unique Entity Identifier • Amount of Subaward • Subaward Obligation/Action Date • Date of Report Submission • Subaward Number • Subaward Project Description • Subawardee Names and Compensation of Highly Compensated Officers, if applicable The information is 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. Additionally, in accordance with federal requirements, a non-federal entity shall maintain internal controls over federal programs designed to provide reasonable assurance that reports are accurately and timely filed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and context: For ALN 19.517, there were 3 new or amended subawardee agreements entered into during fiscal year 2024. We selected all three of these agreements for test work and noted that while all the key data elements were accurately submitted, the information for all three agreements was not submitted timely. All of the agreements were entered into on October 1, 2023 and the information was submitted in January 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for all subawards on a timely basis. We noted the following exceptions: Transactions Tested - 3 Subaward not reported - 0 Report not timely - 3 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $957,943 Subaward not reported - $0 Report not timely - $957,943 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 For ALN 98.001, there were 23 new or amended subawardee agreements entered into during fiscal year 2024. We selected four for test work and noted that while all the key data elements were accurately submitted, the information for two of these agreements was not submitted timely. These two agreements were entered into on January 1, 2024 and March 1, 2024 and the information was not submitted until November of 2024. During our testwork over this program, we noted IRC did not establish control procedures to submit FFATA reports for certain subawards on a timely basis. We noted the following exceptions: Transactions Tested - 4 Subaward not reported - 0 Report not timely - 2 Subaward amount incorrect - 0 Subaward incorrect key elements - 0 Dollar Amount of Tested Transactions - $1,349,750 Subaward not reported - $0 Report not timely - $112,617 Subaward amount incorrect - $0 Subaward incorrect key elements - $0 Cause: Responsible staff encountered challenges accessing SAM.gov due to credential errors, which resulted in delays in submitting or updating subrecipient details in a timely manner. Effect: Delayed reporting can lead to reduced transparency, hindering public access to information about how federal funds are being used. Questioned Costs: None. Recommendation: IRC should continue to communicate to all field office personnel responsible for FFATA submissions the importance of timely reporting. We recommend adding another level of review from headquarters to ensure reporting is taking place once a subawardee agreement is finalized. Views of Responsible Officials: Management agrees with this finding and will take the necessary actions to ensure its FFATA reporting is more timely.

Corrective Action Plan

2024-001 Reporting - Federal Funding Accountability and Transparency Act 2024-001 Reporting - Federal Funding Accountability and Transparency Act Federal Agencies: U.S. Department of State/Bureau of Population and Refugees and Migration, and U.S. Agency for International Development Program Titles and ALN Numbers: 1.ALN #19.517: Overseas Refugee Assistance Programs for Africa 2.ALN #98.001: United States Foreign Assistance for Programs Overseas Federal Grant Numbers: 1. SPRMCO23CA0106 - Advancing access to integrated life-saving assistance and protection services to promote self-reliance and resilience for refugees and host communities in Uganda 2. 720BHA22GR00304 - Holistic prevention and response services to support people affected by forced displacement to restore and rebuild their lives Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to ensure timely FFATA reporting of all applicable subgrant details in SAM.Gov: 1.IRC will update its onboarding process descriptions and checklists to ensure all staff responsible for FFATA reporting are provided the Sam.Gov credentials required for entering data into the system within 15 days of starting. 2.All staff responsible for entering FFATA details in Sam.Gov will be provided additional training and user guides detailing FFATA reporting requirements and processes. The updated process requirements will require obtaining screenshots when system errors/access prevents entering details within the required 30 days. 3.Quarterly detective review processes will be put in place to monitor compliance with all FFATA compliance and corrective actions will be taken with staff who are not performing to standard. Anticipated Completion Date: September 30, 2025

Categories

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Other Findings in this Audit

  • 560217 2024-002
    Significant Deficiency
  • 560218 2024-002
    Significant Deficiency
  • 560219 2024-002
    Significant Deficiency
  • 560220 2024-002
    Significant Deficiency
  • 560221 2024-002
    Significant Deficiency
  • 560222 2024-002
    Significant Deficiency
  • 560223 2024-002
    Significant Deficiency
  • 560224 2024-002
    Significant Deficiency
  • 560225 2024-002
    Significant Deficiency
  • 560226 2024-002
    Significant Deficiency
  • 560227 2024-002
    Significant Deficiency
  • 560228 2024-002
    Significant Deficiency
  • 560229 2024-002
    Significant Deficiency
  • 560230 2024-002
    Significant Deficiency
  • 560231 2024-002
    Significant Deficiency
  • 560232 2024-002
    Significant Deficiency
  • 560233 2024-002
    Significant Deficiency
  • 560234 2024-002
    Significant Deficiency
  • 560235 2024-002
    Significant Deficiency
  • 560236 2024-002
    Significant Deficiency
  • 560237 2024-002
    Significant Deficiency
  • 560238 2024-002
    Significant Deficiency
  • 560239 2024-002
    Significant Deficiency
  • 560240 2024-002
    Significant Deficiency
  • 560241 2024-002
    Significant Deficiency
  • 560242 2024-002
    Significant Deficiency
  • 560243 2024-002
    Significant Deficiency
  • 560244 2024-002
    Significant Deficiency
  • 560245 2024-002
    Significant Deficiency
  • 560246 2024-002
    Significant Deficiency
  • 560247 2024-002
    Significant Deficiency
  • 560248 2024-002
    Significant Deficiency
  • 560249 2024-002
    Significant Deficiency
  • 560250 2024-002
    Significant Deficiency
  • 560251 2024-002
    Significant Deficiency
  • 560252 2024-002
    Significant Deficiency
  • 560253 2024-002
    Significant Deficiency
  • 560254 2024-001
    Significant Deficiency
  • 1136658 2024-001
    Significant Deficiency
  • 1136659 2024-002
    Significant Deficiency
  • 1136660 2024-002
    Significant Deficiency
  • 1136661 2024-002
    Significant Deficiency
  • 1136662 2024-002
    Significant Deficiency
  • 1136663 2024-002
    Significant Deficiency
  • 1136664 2024-002
    Significant Deficiency
  • 1136665 2024-002
    Significant Deficiency
  • 1136666 2024-002
    Significant Deficiency
  • 1136667 2024-002
    Significant Deficiency
  • 1136668 2024-002
    Significant Deficiency
  • 1136669 2024-002
    Significant Deficiency
  • 1136670 2024-002
    Significant Deficiency
  • 1136671 2024-002
    Significant Deficiency
  • 1136672 2024-002
    Significant Deficiency
  • 1136673 2024-002
    Significant Deficiency
  • 1136674 2024-002
    Significant Deficiency
  • 1136675 2024-002
    Significant Deficiency
  • 1136676 2024-002
    Significant Deficiency
  • 1136677 2024-002
    Significant Deficiency
  • 1136678 2024-002
    Significant Deficiency
  • 1136679 2024-002
    Significant Deficiency
  • 1136680 2024-002
    Significant Deficiency
  • 1136681 2024-002
    Significant Deficiency
  • 1136682 2024-002
    Significant Deficiency
  • 1136683 2024-002
    Significant Deficiency
  • 1136684 2024-002
    Significant Deficiency
  • 1136685 2024-002
    Significant Deficiency
  • 1136686 2024-002
    Significant Deficiency
  • 1136687 2024-002
    Significant Deficiency
  • 1136688 2024-002
    Significant Deficiency
  • 1136689 2024-002
    Significant Deficiency
  • 1136690 2024-002
    Significant Deficiency
  • 1136691 2024-002
    Significant Deficiency
  • 1136692 2024-002
    Significant Deficiency
  • 1136693 2024-002
    Significant Deficiency
  • 1136694 2024-002
    Significant Deficiency
  • 1136695 2024-002
    Significant Deficiency
  • 1136696 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.567 Refugee and Entrant Assistance Voluntary Agency Programs $20.37M
93.067 Global Aids $8.05M
97.141 Shelter and Services Program $2.95M
19.518 Overseas Refugee Assistance Programs for Western Hemisphere $1.48M
59.077 Community Navigator Pilot Program $1.36M
10.234 American Rescue Plan Technical Assistance Investment Program $816,568
21.027 Coronavirus State and Local Fiscal Recovery Funds $805,467
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $572,959
93.604 Assistance for Torture Victims $561,541
19.108 Bureau of South and Central Asian Affairs $519,255
19.223 South Sudan and Sudan Assistance Program $304,786
19.345 International Programs to Support Democracy, Human Rights and Labor $290,982
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $290,706
19.522 Overseas Refugee Assistance Programs for Strategic Global Priorities $276,851
59.050 Prime Technical Assistance $253,252
94.021 Americorps Volunteer Generation Fund 94.021 $230,393
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $208,051
16.582 Crime Victim Assistance/discretionary Grants $198,518
98.001 Usaid Foreign Assistance for Programs Overseas $195,052
19.519 Overseas Refugee Assistance Program for Middle East and North Africa Program $176,987
97.102 Case Management Pilot Program $172,982
19.523 Overseas Refugee Assistance Program for South Asia $167,813
10.902 Soil and Water Conservation $162,613
10.935 Urban Agriculture and Innovative Production $158,111
98.U03 Catalyze Capital Investment Platform $150,829
10.175 Farmers Market and Local Food Promotion Program $149,337
16.575 Crime Victim Assistance $139,533
93.898 Cancer Prevention and Control Programs for State, Territorial and Tribal Organizations $136,337
82.002 Educational Exchange_university Lecturers (professors) and Research Scholars $133,755
84.287 Twenty-First Century Community Learning Centers $125,879
10.225 Community Food Projects $121,718
97.010 Citizenship Education and Training $110,350
84.002 Adult Education - Basic Grants to States $109,159
10.255 Research Innovation and Development Grants in Economic (ridge) $100,130
84.424 Student Support and Academic Enrichment Program $98,672
10.522 Food and Agriculture Service Learning Program $87,618
19.517 Overseas Refugee Assistance Programs for Africa $86,951
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $85,653
17.259 Wioa Youth Activities $72,402
93.495 Community Health Workers for Public Health Response and Resilient $70,264
93.676 Unaccompanied Children Program $64,539
93.327 Demonstration Grants for Domestic Victims of Human Trafficking $61,265
59.037 Small Business Development Centers $60,000
19.511 Overseas Refugee Assistance Programs for East Asia $58,511
10.182 Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments $53,141
10.170 Specialty Crop Block Grant Program - Farm Bill $51,928
21.023 Emergency Rental Assistance Program $43,499
93.569 Community Services Block Grant $42,500
10.551 Supplemental Nutrition Assistance Program $38,978
32.011 Affordable Connectivity Outreach Grant Program $38,616
10.215 Sustainable Agriculture Research and Education $37,239
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $28,766
19.510 U.s. Refugee Admissions Program $28,624
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $27,055
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $25,155
93.583 Refugee and Entrant Assistance Wilson/fish Program $24,468
93.598 Services to Victims of A Severe Form of Trafficking $19,981
21.009 Volunteer Income Tax Assistance (vita) Matching Grant Program $19,586
84.425 Education Stabilization Fund $19,163
21.034 State Small Business Credit Initiative Competitive Technical Assistance Program $16,825
98.U01 Latin America and Caribbean Learning and Rapid Response Task Order (laclearn) $16,027
17.289 Community Project Funding/congressionally Directed Spending $15,000
93.283 Centers for Disease Control and Prevention Investigations and Technical Assistance $15,000
19.019 International Programs to Combat Human Trafficking $14,948
10.443 Outreach and Assistance for Socially Disadvantaged and Veteran Farmers and Ranchers $14,085
16.320 Services for Trafficking Victims $13,130
10.675 Urban and Community Forestry Program $11,412
93.575 Child Care and Development Block Grant $10,131
98.U02 Improving Learning Outcomes for Asia Mechanism (iloa) $8,650
93.493 Congressional Directives $5,899
97.024 Emergency Food and Shelter National Board Program $5,250
17.258 Wioa Adult Program $4,923
93.558 Temporary Assistance for Needy Families $4,281
10.331 Gus Schumacher Nutrition Incentive Program $4,124
10.575 Farm to School Grant Program $3,645
10.311 Beginning Farmer and Rancher Development Program $3,469
94.006 Americorps State and National 94.006 $571
93.584 Refugee and Entrant Assistance Targeted Assistance Grants $239
93.576 Refugee and Entrant Assistance Discretionary Grants $-43
14.218 Community Development Block Grants/entitlement Grants $-44
98.U04 2020-Catalyst-Ga016 Safe to Learn and Thrive Together $-3,424
93.556 Marylee Allen Promoting Safe and Stable Families Program $-155,057