Finding Text
Finding 2023-002: Federal Funding Accountability and Transparency Act (FFATA) Reporting
Information on the Federal Programs: Assistance Listing Number 19.518
Criteria: The FFATA Subaward Reporting System (FSRS) is the reporting tool Federal prime
awardees use to capture and report subaward and executive compensation data regarding their firsttier
subawards to meet the FFATA reporting requirements. Prime Awardees awarded a Federal grant
are required to file a FFATA sub-award report by the end of the month following the month in which the
prime awardee awards any sub-grant equal to or greater than $30,000. Criteria (continued): CFR 200.332(a) states that entities must ensure that every subaward is clearly
identified to the subrecipient as a subaward and includes information related to the Federal award
project description, as required to be responsive to FFATA. CFR 200.341(c) states that the entity must
provide the information required under FFATA to the Federal website established to fulfill the
requirements of FFATA, and update or notify any other relevant governmentwide systems or entities of
any indications of poor performance (or issues related to suspension or debarment).
Condition: Asylum Access has not complied with the aforementioned criteria (we noted no evidence
of a FFATA reporting process).
Cause: Asylum Access does not maintain documented policies regarding FFATA reporting and
therefore compliance with Federal regulations cannot be determined.
Context: Absent proper policies and procedures, Asylum Access is at risk of entering into sub-awards
under Federal awards that were not properly reported and therefore could result in noncompliance with
FFATA requirements.
Effect: Asylum Access did not comply with the requirements noted above.
Questioned Costs: None noted.
Identification as a Repeat Finding: N/A
Recommendation: We recommend Asylum Access establish a FFATA reporting policy to become
compliant with the aforementioned requirements. We further recommend it ensure all staff are properly
trained with respect to the new policy to ensure compliance. In cases where Asylum Access is exempt
from reporting or qualifies for a reporting waiver, that conclusion should be documented in its subgrantee
records.