Finding Text
Finding 2024-005 Federal Funding Accountability and Transparency Act (FFATA) Subaward
Reporting (Significant Deficiency)
Information on the Federal Programs: ALN #19.510 U.S. Refugee Admissions Program, ALN
#93.567 Refugee and Entrant Assistance Voluntary Agency Programs
Criteria or Specific Requirement: As noted in 2 CFR Part 170, recipients (i.e. direct recipients) of
grants or cooperative agreements who make first tier subawards of $30,000 or more are required to
register in the Federal Funding Accountability and Transparency Act Subaward Reporting System
(FSRS) and report subaward data through FSRS. Prime awardees are required to file a FFATA subaward
report by the end of the month following the month in which the prime recipient awards any
subaward with a value greater than or equal to $30,000.
Condition: During our audit, we noted six cases in which the required subaward reporting was not
completed within the required timeframe (the reports were ultimately filed late). Additionally, we noted
that HIAS does not have a process to formally document the internal controls with respect to the review
and approval of FFATA reports prior to submission.
Cause: Administrative oversight.
Effect or Potential Effect: Noncompliance with FFATA reporting requirements could potentially result
in withholding of future payments, award suspension or termination, and ineligibility for future awards.
Questioned Costs: N/A
Context: Our testwork consisted of a sample of sixteen subawards. Late reporting was noted for six of
the sixteen subawards tested. The control deficiency is considered systemic in nature.
Identification as a Repeat Finding: N/A
Recommendation: We recommend that management take steps to raise awareness of the FFATA
reporting deadlines to those staff responsible for maintaining compliance with FFATA reporting
requirements. Additionally, we recommend that HIAS enhance documentation related to review and
approval of such reports prior to submission.