AFT remains committed to maintaining an effective system of internal control over financial reporting and
compliance. To that end, AFT has taken the following corrective actions to ensure appropriate and timely
compliance with FFATA filing requirements.
1. F&A Staff reviewed FFATA Training Resources and SAM.gov resources
o Ongoing Staff Training of F&A staff and staff identified in item 4.
2. Updated AFT’s Subawards Manual. The purpose of the Subawards Manual document is to assist in the
preparation, administration, and management of AFT issued subawards. The Subaward Manual
identifies the roles and responsibilities of AFT staff throughout the subaward lifecycle.
3. Updated Subaward Template FFATA Reporting Requirements and Data Collection
4. To ensure timely compliance with FFATA reporting requirements
o Designated Contract Administrator with responsibility to file FFATA reports in connection with
the execution and delivery of any subaward which occurs through our contracts management
system
o Will designate grant management staff to confirm filing
5. F&A Remediation
o F&A is pulling the Schedule of Expenditures of Federal Awards (SEFA) data for FY22, FY23, and
FY24 to determine which prime grants may have had subawards
o Identify subaward agreements that require FFATA filing
If AFT does not have the required information to make FFATA, AFT program, project,
and/or finance staff will be tasked with obtaining the information
o Make the required FFATA reports on SAM.gov
6. AFT will continue to monitor compliance with the updated procedures and FFATA requirements on a
quarterly basis.
o Using shared resources, finance will work with the Administrative Coordinator to verify that
tracked information for issued subawards resulted in timely filing.