Finding Text
Finding 2024 – 001: FFATA Controls
Significant Deficiency
Federal Program: USAID Foreign Assistance for Program Overseas (ALN 98.001)
Federal Awarding Agency: United States Agency for International Development
Awards:
• Direct award: Resilient Coastal Community – 72065622CA00010
• Direct award: Urban Sanitation Activity – 72068724CA00001
• Pass-Through from UC Davis – A23-3500-S001
• Pass-Through from Project Concern International – PCI-1203-SG-1600
Criteria: 2 CFR 200.303 states that a receipt or subrecipient of federal awards must establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient or subrecipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should align with the guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition: There is no internal control in place over Federal Funding Accountability and Transparency Act (FFATA) reporting submissions, which is a direct and material compliance requirement over USAID federal awards.
Context: The lack of control in place over FFATA submissions did not result in any instances of noncompliance with FFATA reporting requirements. The lack of an internal control in place over FFATA submissions resulted in a significant deficiency in internal controls over the FFATA compliance requirement due to potential for future noncompliance.
Cause: Policies and procedures documents do not include controls for FFATA report submissions.
Effect: The lack of control around FFATA submissions could result in missed reporting requirements resulting in potential delays in award processing and discontinued funding.
Questioned costs: None
Repeat finding? No
Recommendation: We recommend management implement a control over FFATA submissions that includes evidence of that control taking place (signature, email approval, etc.).
Views of Responsible Officials: Management agrees with the finding. See corrective action plan.