Finding 571802 (2024-003)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2024
Accepted
2025-07-23
Audit: 362812
Organization: Council of Graduate Schools (DC)
Auditor: Aprio LLP

AI Summary

  • Core Issue: The organization failed to report a $30,000 subaward in the FFATA Subaward Reporting System, violating federal compliance requirements.
  • Impacted Requirements: Noncompliance with 2 CFR 170.200 and 2 CFR Part 170 Appendix A regarding timely subaward reporting can jeopardize future federal funding.
  • Recommended Follow-Up: Implement formal procedures for tracking subawards, train staff on reporting requirements, and conduct monthly reviews of FFATA reporting status.

Finding Text

Finding 2024-003: Reportable Finding Considered a Significant Deficiency – FFATA Reporting Compliance Program Name: NSF Technology, Innovation, and Partnerships Assistance Listing #: 47.084 Program Year: 2024 Federal Awarding Agency: National Science Foundation Compliance Requirement: Reporting Criteria: In accordance with 2 CFR 170.200 and 2 CFR Part 170 Appendix A, prime recipients of federal grants that make first-tier subawards of $30,000 or more must report subaward data through the FFATA Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward obligation was made. Condition: During our audit, we selected 6 first-tier sub awards for testing. One subaward was for $30,000 and it was determined that it had not been reported in the FSRS. Cause: The Organization was unaware of the FFATA reporting requirements and lacked internal policies and procedures to ensure timely and accurate reporting of subawards. Effect: Failure to comply with FFATA reporting requirements may result in noncompliance with federal grant terms and could impact future federal funding eligibility. Questioned Costs: None. Repeat finding: This is not a repeat finding. Recommendation: We recommend that the Organization establish formal procedures to identify and track subaward obligations that meet the FFATA reporting threshold. Designated personnel should be trained on the reporting requirements, and reporting deadlines should be incorporated into the grants management calendar. Additionally, management should review FFATA reporting status monthly to ensure ongoing compliance. Views of Responsible Officials and Planned Corrective Action (unaudited): See Corrective Action Plan.

Corrective Action Plan

Description:Significant deficiency in FFATA reporting threshold. Planned Corrective Action: CGS will familiarize itself with all FFATA reporting requirements to ensure that the $30,000.00 threshold for first-tier subawards will be reported to FSRS with all reporting deadlines observed by building this requirement into the grants management calendaring system. Completion Date: October 1, 2025 Responsible Person: Keith Peregonov, VP for Finance, Human Resources and Operations

Categories

Subrecipient Monitoring Eligibility Reporting Significant Deficiency

Other Findings in this Audit

  • 571788 2024-001
    Significant Deficiency
  • 571789 2024-001
    Significant Deficiency
  • 571790 2024-001
    Significant Deficiency
  • 571791 2024-001
    Significant Deficiency
  • 571792 2024-001
    Significant Deficiency
  • 571793 2024-001
    Significant Deficiency
  • 571794 2024-002
    Significant Deficiency
  • 571795 2024-002
    Significant Deficiency
  • 571796 2024-002
    Significant Deficiency
  • 571797 2024-002
    Significant Deficiency
  • 571798 2024-002
    Significant Deficiency
  • 571799 2024-002
    Significant Deficiency
  • 571800 2024-002
    Significant Deficiency
  • 571801 2024-002
    Significant Deficiency
  • 571803 2024-003
    Significant Deficiency
  • 1148230 2024-001
    Significant Deficiency
  • 1148231 2024-001
    Significant Deficiency
  • 1148232 2024-001
    Significant Deficiency
  • 1148233 2024-001
    Significant Deficiency
  • 1148234 2024-001
    Significant Deficiency
  • 1148235 2024-001
    Significant Deficiency
  • 1148236 2024-002
    Significant Deficiency
  • 1148237 2024-002
    Significant Deficiency
  • 1148238 2024-002
    Significant Deficiency
  • 1148239 2024-002
    Significant Deficiency
  • 1148240 2024-002
    Significant Deficiency
  • 1148241 2024-002
    Significant Deficiency
  • 1148242 2024-002
    Significant Deficiency
  • 1148243 2024-002
    Significant Deficiency
  • 1148244 2024-003
    Significant Deficiency
  • 1148245 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
47.084 Nsf Technology, Innovation, and Partnerships $2.16M
47.076 Stem Education (formerly Education and Human Resources) $15,904