Finding Number: 2024-002
Recommendation: Inform subrecipients of the required federal award info outlined in § 200.332 Requirements
for pass-through entities.
Action Taken:
1. AANA has posted on its MAST website and application that: “The MAST program is funded by the
United States Federal Government and is subject to all applicable federal statutes, regulations, and
requirements. The receiving entity is not debarred, suspended, or otherwise excluded from using
federal funds.”
2. AANA will include the following as a footnote on any MAST manuscripts and printed text: “Supported by
a grant administered by The Arthroscopy Association of North America (AANA), with funding provided
by the Military Advanced Surgical Treatment (MAST) Program.”
3. Request and/or ensure the following information through the contracting process with any MAST
Subrecipient:
a. Subrecipient's name (must match the name associated with its unique entity identifier)
b. Subrecipient's unique entity identifier
c. Subaward Period of Performance Start and End Date
d. Subaward Budget Period Start and End Date
e. Amount of Federal Funds Obligated in the subaward
f. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity,
including the current financial obligation
g. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity
h. Federal award project description, as required by the Federal Funding Accountability and
Transparency Act (FFATA)
i. Identification of whether the Federal award is for research and development
j. Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance
with § 200.414)
i. An approved indirect cost rate negotiated between the subrecipient and the Federal
Government. If no approved rate exists, a pass-through entity must determine the
appropriate rate in collaboration with the subrecipient. The indirect cost rate may be
either:
1. An indirect cost rate negotiated between the pass-through entity and the
subrecipient. These rates may be based on a prior negotiated rate between a
different pass-through entity and the subrecipient, in which case the passthrough
entity is not required to collect information justifying the rate but may
elect to do so; or
2. The de minimis indirect cost rate.
k. A requirement that the subrecipient permit the pass-through entity and auditors to access the
subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring
requirements
l. Verify that a subrecipient is audited as required
Responsible Contact Person for Planned Corrective Action: Dennis Siena
Anticipated Completion Date: September 30, 2025