Finding 624409 (2022-002)

Condition: During our test for compliance with the Federal Funding Accountability and Transparency Act (FFATA), we noted that the School District of Philadelphia (School District) did not have a process in place to report subawards made under the federal Head Start program in accordance with the FFATA and award agreement. Consequently, auditors could not test for FFATA reporting compliance for this grant program. Funding for this program is from the Department of Health and Human Services. Criteria: Per the OMB?s Uniform Guidance 2 CFR Part 170, the prime recipient of a federal award must report information regarding first-tier subawards of $30,000 or more utilizing the FFATA Subaward Reporting System (FSRS), and states that the subaward reporting requirement applies to all types of first-tier subawards. The reporting is required by the end of the month following the month in which the award is made. Effect: Federal grantors may not have complete and accurate information to make fiscal decisions on federal awards. Additionally, there could be a lack of transparency and accountability to the public on how federal dollars are spent. Cause: School District management was not aware of the FFATA reporting requirement. Therefore, School District management did not have a systematic process in place to report subawards made under the federal Head Start program in accordance with FFATA. Recommendation: School District?s management should develop written policies and procedures which ensure that it complies with the FFATA requirement to file first-tier subaward reports.