Finding 576745 (2022-001)

Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Federal Agency: HHS AL Numbers and Titles: 93.592 - Family Violence Prevention and Services/Discretionary Federal Award Number: 90EV0531 Questioned Costs: None Repeat Finding: No Criteria: 2 CFR §200.303 – Internal Controls of the Uniform Guidance states 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 or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR §170 requires non‐Federal entities making first‐tier subawards of Federal funding to comply with the reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA) (Public Law 109‐282), as amended by section 6202 of Public Law 110‐252. Compliance with FFATA requires prime recipients to report subaward and executive compensation data about the sub‐awards to the FFATA Subaward Reporting System (FSRS) by the end of the month following the month in which the subaward obligation was made, if the subaward amount is greater than or equal to $30,000. Condition: We reviewed all subawards made by the grantee during the audit period and found that 4 of them, totaling $224,000, were not reported to the FSRS. Cause: Caminar Latino did not have adequate policies and procedures to ensure timely and accurate reporting of subaward data to the FSRS. Effect: The grantee did not comply with the FFATA reporting requirement, which could result in a lack of transparency and accountability for the use of Federal funds. Recommendation: We recommend Caminar Latino develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Views of Responsible Officials Corrective Actions: Caminar Latino, Inc. agrees with this finding. Please refer to the Corrective Action Plan.