Finding Text
Finding 2022-011 Lack of Internal Control over Compliance and Noncompliance Special Reporting
Federal Agencies: U.S. Department of Education
Federal Programs: Alaska Native Education Program
Assistance Listing Numbers: 84.356A
Award Numbers: 356A210011
Award Years: 2022
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Title 2 CFR 200.303 requires the Council to establish and maintain effective internal control over the federal award that provides reasonable assurance that the Council is managing the federal award in compliance with federal statutes, regulations, and terms and conditions of the grant awards. Title 2 CFR 170 states federal award recipients are required to report each subaward that obligates $30,000 or more in federal funds. This information must be reported no later than the end of the month following the month in which the obligation was made and must include information about each obligating action in accordance with submission instructions.
Condition and Context: FY22 Federal Funding Accountability and Transparency Act (FFATA) subaward reporting for Alaska Native Education Programs did not occur for one subaward. FFATA Requires information on federal awards to be made available to the public via a single searchable website (www.usaspending.gov). The FFATA Subaward Reporting System (FSRS) is the reporting tool federal awardees use to capture and report subawards regarding first-tier subawards.
Cause: Lack of internal control over special reporting.
Effect: Failure to comply with FFATA reporting requirements reduces transparency, impairs decision-making, and may potentially jeopardize future federal funding.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding. However, we believe this to be a systematic issue.
Recommendation: We recommend the Council develop FFATA reporting policies and procedures to submit subaward information through FSRS to ensure compliance with FFATA requirements.
Management’s Response: Management concurs with this finding. See Corrective Action Plan.