Finding 585482 (2023-001)

Noncompliance and Significant Deficiency in Internal Controls over Compliance for Reporting Identification data: U.S. Department of Health and Human Services (HHS) – Mental and Behavioral Health Education and Training Grants, Assistance Listing No. 93.732, Agreement Identifying No. M0142518. Criteria: Appendix A to Part 170 of Title 2 CFR, Subtitle A, Chapter 1 describes the first-tier subaward reporting requirements under the Federal Funding Accountability and Transparency Act (FFATA), which requires prime recipients to report first-tier subawards to non-Federal entities equal to or exceeding $30,000 within 30 days. Condition: The Organization failed to report its first-tier subawards subject to FFATA requirements within the 30 day period. Cause: A breakdown in the Organization’s internal controls over reporting did not allow the Organization to meet the reporting requirements of the program. Effect or potential effect: The control deficiency is a significant deficiency that prevented the Organization from complying with the reporting requirements of the program. Identification of a Repeat Finding: New finding. Recommendation: The Organization should review its system of internal controls over reporting to determine improvements that can be made to ensure the Organization actively tracks and adheres to reporting requirements outlined in its award agreements and included in the CFR. Views of Responsible Officials: The Organization was not aware of the FFATA reporting requirements. The Organization has reviewed FFATA reporting requirements and has adopted a procedure to ensure such reporting is completed as required.