Finding Text
Finding 2022-001 Significant Deficiency in Internal Control over Compliance ? Reporting Criteria: An entity?s internal control structure should include such controls to ensure timely, accurate, and complete reporting. Federal grant recipients are subject to special reporting requirements, including: - Special reports required by the Federal Funding Accountability and Transparency Act (FFATA) which requires subawards in excess of $30,000 to be reported to FSRS no later than the end of the month following the month the subaward was made. - Annual financial reporting includes: o Reports to negotiate the final indirect cost rate proposal based on actual expenditures should be submitted within six months of fiscal year end. o The OMB reporting package containing the data collection form and audit report(s) are required to be submitted to the Federal Clearinghouse the earlier of 30 days after receipt of the auditor?s report(s) or 9 months after the end of the fiscal year. Condition: Reports required by FFATA for sub-awards made in fiscal year 2022 were not completed. Annual financial reports for indirect costs and the OMB reporting package have not yet been submitted. Context: The condition was noted as part of our documentation of internal control processes and substantive testing of compliance with the compliance requirement reporting. Cause: Reports to FSRS were not submitted because the determination of which subawards were subject to FFATA reporting was misinterpreted as the payment of federal award funds to subawardees rather than the execution of the subaward. Report submissions for the annual financial reports for indirect costs and the OMB reporting package were delayed due to the unavailability of a fully adjusted accrual basis trial balance and general ledger. Effect or Potential Effect: MARAMA may not be in compliance with its reporting requirements. Delays in submission of reports could cause delays in the assignment or approval of final and provisional indirect cost rates. Noncompliance with reporting requirements could impact current and future federal awards. Recommendation: MARAMA should develop procedures to ensure subawards are reported to FSRS by the reporting deadline. Accounting records should be finalized more expeditiously in order to allow for timely filing of all annual financial reports. Responsible Official?s Response: MARAMA appreciates the auditor pointing out this issue so that future confusion is avoided. As noted above, the subaward determination may have been misinterpreted due to MARAMA?s understanding of identifying sub awardees. The identifying of the relationship between MARAMA and organizations that we work with will be reviewed so that proper reporting can be accomplished. In addition, due to exceptional demands on the existing financial accounting provider MARAMA was unable to provide timely information to the auditor to meet their schedule constraints. Regardless, MARAMA is transitioning to another financial accounting service provider and will work in developing the necessary steps to provide the auditor with timely information.