Finding 62139 (2022-001)

Material Weakness
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-03-28

AI Summary

  • Core Issue: The Foundation failed to report sub-award information to the FFATA Subaward Reporting System on time, indicating a material weakness in internal controls.
  • Impacted Requirements: Non-compliance with 2 CFR section 200.303 and 2 CFR Part 170 regarding internal controls and timely reporting of subawards.
  • Recommended Follow-up: Develop and implement robust control policies to ensure accurate and timely reporting of sub-award information to the FSRS.

Finding Text

Finding 2022-001: Reporting Requirements Program Name: Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects - Assistance Listing No. 93.185 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security - Assistance Listing No. 93.318 Awarding Agency: U.S. Department of Health and Human Services Finding Type: Material Weakness on Internal Controls over Compliance and Material instance of Non-compliance Questioned Costs: None Context / Criteria: 2 CFR section 200.303 ? Internal Controls of the Uniform Guidance states that the non-federal entity must: (a) Establish and maintain effective internal controls over 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 Part 170 requires non-Federal entities making first-tier subawards of Federal funding to comply with 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 FAFATA requires prime recipients, such as the Foundation, to report certain information about the sub-awards to the FFATA Subaward Reporting System (FSRS) by the end of the month, plus 30 days, in which the award is made. Condition: The Foundation did not report required information about subawards made under Assistance Listing No. 93.185 and Assistance Listing No. 93.318 to the FSRS as required by FFATA within the timeline required. Cause / Effect: The Foundation lacks established internal controls to ensure accurate and timely sub-award information is reported to the FSRS. Recommendation: We recommend the Foundation 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 and Corrective actions: Management is in agreement with the finding. See accompanying Corrective Action Plan.

Corrective Action Plan

Finding 2022-01: Reporting Requirements Name of contact person: Nedra Jones, CFO Recommendation: We recommend the Foundation develop and implement adequate control policies and procedures to ensure accurate and timely subaward information is reported to the FSRS as required by FFATA. Corrective Action: During the 2021-2022 fiscal year, the Foundation acknowledges that subaward information was not reported timely, as stipulated by FFATA. Pursuant to FFATA requirements, the Foundation has now implemented a policy and procedures to ensure accurate and timely submissions. Note that all monitoring to ensure that expenditures made by subrecipients were allowable under the applicable awards and regulatory guidance was, and continues to be, handled by the Foundation. Effective March 2023, the Foundation will submit data, as required, within 30 days after an award is received and subawards are subsequently made. All subaward data submissions are and will continue to be reviewed and subsequently approved by multiple staff, across our Legal, Finance, and Internal Operations departments. To ensure compliance with the FFATA reporting requirement, once an award is approved and subaward agreements, over the threshold of $30,000, are executed, the Foundation will employ a collaborative approach wherein the Grants Coordinator (Federal Grants and Compliance) will confer with the Federal Finance Manager (Finance) to review subaward data requirements. Once the list of sub awards to be reported is identified and approved, the reports will be submitted into FSRS. A copy of the completed data for that period, will be uploaded into the Foundation?s CRM, Salesforce, where this data will be housed under the applicable record. Proposed Completion Date: March 2023 and ongoing.

Categories

Subrecipient Monitoring Material Weakness Reporting

Other Findings in this Audit

  • 62140 2022-001
    Material Weakness
  • 62141 2022-001
    Material Weakness
  • 62142 2022-001
    Material Weakness
  • 638581 2022-001
    Material Weakness
  • 638582 2022-001
    Material Weakness
  • 638583 2022-001
    Material Weakness
  • 638584 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
93.421 Covid-19 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $173.03M
93.185 Covid-19 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $27.46M
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $2.31M
93.283 Centers for Disease Control and Prevention_investigations and Technical Assistance $1.29M
93.318 Covid-19 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $860,763
10.310 Agriculture and Food Research Initiative (afri) $181,563
93.136 Injury Prevention and Control Research and State and Community Based Programs $166,405
97.044 Assistance to Firefighters Grant $122,807
93.226 Research on Healthcare Costs, Quality and Outcomes $116,906
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nations Health $91,624
93.855 Allergy, Immunology and Transplantation Research $83,603
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $49,576
93.865 Child Health and Human Development Extramural Research $25,553