Finding Text
Finding 2023-003 – Reporting – Federal Accountability and Transparency Act Subaward Reporting System (FFATA)
Repeat Finding: No
Federal Program Title – U.S. Department of Defense
Cybersecurity Core Curriculum 12.905
Condition
For one out of one subawards tested (100%), the College did not report subaward data to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS).
Transactions Tested Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
1 1 0 0 0
Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amount incorrect Subaward missing key elements
$ 75,000 $ 75,000 $ 0 $ 0 $ 0
Criteria
Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by section 6202 of Public Law 110-252, hereafter referred as the “Transparency Act” that are codified in 2 CFR Part 170, recipients (i.e., direct 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). The non-federal entity is required to report each obligating action to FSRS. The action must be reported in FSRS no later than the last day of the month following the month in which the subaward/subaward amendment was made.
Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls deigned to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure reports are submitted timely.
Questioned Costs
There were no questioned costs related to reporting.
Cause
The College misinterpreted the absence of Department of Defense NSA CFDA # / ALN # 12.905 from the Compliance Supplement Compliance Matrix as an indication that this award was not subject to the subrecipient monitoring components of the Uniform Guidance and the Compliance Supplement.
Prevalence
Frequent. One out of one subawards selected for testing.
Effect
Without proper program reporting policies and procedures, the submission of late reports is noncompliance with Federal regulation and could result in the loss of future funding.
Recommendation
We recommend the College review current processes, policies and procedures to ensure Federal Funding Accountability and Transparency Act reporting requirements are completed timely.
Views of responsible officials
We agree with this finding. See corrective action plan.