Finding Text
Finding 2024-001 Federal Funding Accountability and Transparency Act (FFATA) Reporting
Identification of the federal program:
Federal Grantor: United States Department of Health and Human Services
Assistance Listing No.: 93.817 Hospital Preparedness Program (HPP) Ebola Preparedness and Response Activities
Criteria or specific requirement (including statutory, regulatory, or other citation):
2 CFR 200.303 requires that the non-Federal entity must “(a) establish and maintain effective internal control over the Federal award that provides 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. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the comptroller General of the United States and the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).”
Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282) (Transparency Act) that are codified in 2 CFR Part 170, “unless the auditee is exempt as provided in paragraph d. of this award term, the auditee must report each action that equals or exceeds $30,000 in Federal funds for a subaward to a non-Federal entity or Federal agency no later than the end of the month following the month in which the obligation was made.” 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) per submission instructions posted at http://www.fsrs.gov.
Condition:
During our testing of FFATA Report, it was identified that the report was not submitted by Fairview management within the time frame designated in 2 CFR 170 Appendix A.
Cause:
Policies and procedures and internal controls were not in place to ensure compliance with the FFATA reporting requirements.
Effect or potential effect:
Fairview Health Services did not report the necessary FFATA report for first-tier subawards over $30,000 to the FFATA Subaward Reporting System.
Questioned costs:
None.
Context:
Total subrecipient expenditures subject to FFATA reporting were $155,996 for the year ended December 31, 2024 and total Federal expenditures were $1,656,727 for the year ended December 31, 2024.
Identification as a repeat finding, if applicable:
The finding is not a repeat finding from the prior year.
Recommendation:
We recommend that Fairview Health Services management take immediate action to ensure compliance with the reporting requirements of the FFATA.
Views of responsible officials:
Management agrees with the finding. The FFATA report was filed on April 15, 2025. Fairview has established an internal control to ensure timely filing of FFATA reports in the future.