FAC Explorer

Finding 565360 (2024-001)

Significant Deficiency Repeat Finding
Requirement
M
Questioned Costs
-
Year
2024
Accepted
2025-06-18
Audit: 359204
Organization: Path (WA)
Auditor: Clark Nuber P S

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance with FFATA reporting requirements, leading to late submissions of reports.
  • Impacted Requirements: The Organization failed to file FFATA sub-award reports on time for 2 out of 10 tested sub-awards, violating federal regulations.
  • Recommended Follow-Up: Management should enhance the review process for FFATA filings to ensure timely submissions and compliance moving forward.

Finding Text

Finding 2024-001 Significant deficiency in internal control over compliance related to reporting for the Federal Funding Accountability and Transparency Act. Federal Agency: United States Agency for International Development Program Title: USAID Malaria Vaccine Assistance Listing Number: 98.AID-7200AA20C00017 Award Number: 7200AA20C00017 Award Period: 06/18/2020 through 06/17/2026 Criteria Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. The prime awardee 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 in total greater than or equal to $30,000. The report must be filed in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition/Context The Organization has an established a process by which to perform FFATA reporting. Among the 10 sub-awards we tested, we found that documentation supporting the FFATA filing indicates late submissions for 2 of the selections. Both were existing sub-awards that were amended during the year. Transactions tested 10, Sub-Award Not Reported 0, Reported Not Timely 2, Sub-Award Amount Incorrect N/A, Sub-Award Missing Key Elements N/A Dollar Amount of Tested Transactions $11,068,072, Sub-Award Not Reported $-, Reported Not Timely $204,097, Sub-Aard Amount Incorrect N/A, Sub-Award Missing Key Elements N/A Cause The late submissions were due to the Organization’s periodic review process not effectively identifying and resolving delinquent FFATA filings. Effect The Organization did not comply with the FFATA sub-award reporting requirements that are codified in Title 2 U.S. Code of Federal Regulations. Questioned Costs None. Repeat Finding Elements of this finding are a repeat of some of the matters noted in Finding 2023-002. Recommendations We recommend management review the timing and frequency of its review process over FFATA filings to ensure all filings are submitted in a timely manner. Views of Responsible Individual and Corrective Action Plan Management agrees with the finding and has provided the accompanying corrective action plan.

Corrective Action Plan

Finding 2024-001 PATH’s Response and Corrective Action Plan PATH has an established process for completing FFATA reporting in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) in compliance with the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. Although PATH complied with all other FFATA reporting requirements, reports for two subawards were not filed by the end of the month following the month in which PATH awarded these sub‐grants greater than or equal to $30,000. For the FFATA filings that were submitted late, the cause was that an employee new to PATH that year who assumed FFATA reporting did not realize her entries were not saving in the system correctly. This issue was discovered as part of a routine management review of PATH’s FFATA reporting. When the issue was discovered, management repeated the training on the Office of Grants and Contract’s (OGC) business process for FFATA reporting with that staff member and assigned another member of the team to review entries in the last week of each month, preventing future late filings. In 2025, OGC Management will add the following actions to the FFATA reporting business process strengthen to ensure all filings are submitted in a timely manner. Action Responsible staff member Due date Repeat training on OGC’s business process for FFATA reporting with the two OGC staff members responsible for FFATA reporting for PATH OGC Management June 30, 2025 Provide monthly report to OGC management by the last day of each month confirming timely reporting OGC Staff responsible for FFATA reporting Throughout 2025

Categories

Subrecipient Monitoring Reporting Significant Deficiency

Other Findings in this Audit

  • 1141802 2024-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
98.001 Usaid Foreign Assistance for Programs Overseas $1.84M
93.067 Global Aids $1.31M
93.494 Global Tuberculosis:developing,evaluating,implementing Evidence-Based and Innovative Approaches to Find, Cure, and Prevent Tuberculosis Globally $825,134
98.RD United States Agency for International Development $709,976
93.RD Department of Health and Human Services, National Institutes of Health $322,692
98.RD Usaid Foreign Assistance for Programs Overseas $173,758
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $122,021
93.989 International Research and Research Training $110,215
93.865 Child Health and Human Development Extramural Research $35,586
93.855 Allergy and Infectious Diseases Research $27,200
93.350 National Center for Advancing Translational Sciences $18,504