Finding Text
Finding 2022-004: Federal Funding Accountability and Transparency Act for Housing Opportunities for Persons with AIDs Program ? Significant Deficiency Program: Housing Opportunities for Persons with AIDs Assistance Listing No.: 14.241 Federal Agency: Department of Housing and Urban Development Award No.: Various Award Year: Fiscal year 2021-2022 Category of Finding: Reporting Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, 2 CFR Appendix A to Part 170 a.2.ii. requires that for subaward information, [the County] needs to report no later than the end of the month following the month in which the obligation was made. (For example, if the obligation was made on November 7, 2010, the obligation must be reported by no later than December 31, 2010.) Condition: For the Housing Opportunities for Persons with AIDs Program, the City did not submit accurate reports in a timely manner. The City did not comply with the requirement to report the information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award modification was made. In addition, there was one report for which the City reported the wrong obligation date in FSRS. Cause: Internal Controls over reporting of Federal Funding Accountability and Transparency Act data were not designed and implemented properly to ensure timely submission of the report and accurate reporting of key data elements. Effect: The City did not have effective controls in place to submit accurate and timely report information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None. Context: During our walkthrough of the internal control assessment of the Federal Funding Accountability and Transparency Act (FFATA) reporting for the grant, we had noted there were no evidence of internal control in place to ensure the FFATA reporting was reported timely in the FSRS portal. We selected a sample of 4 of 15 subawards pertaining to the Housing Opportunities for Persons with Aids grants. Out of the 4 subawards selected, 3 of them were not reported timely as required by the reporting requirement under the criteria. In addition, 3 subawards selected reported an obligation date that was different than the execution date of the subaward agreement. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen their internal controls to ensure timely and accurate submission required under the Federal Funding Accountability and Transparency Act. Management Response: Management agrees that the Federal Funding Accountability and Transparency Act (FFATA) report for the Housing Opportunities for Persons with AIDs Program for three sub-awards was not submitted by the last day of the month following the month in which the sub-award was made, and three of the obligation dates reported were incorrect. The FFATA report was prepared and filed by the Neighborhood Services Administrator. Management will implement a process where Grant Coordinators will prepare the report and the Grant Administrator will review the information for accuracy and input the data into the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). The Neighborhood Services Administrator will review the report and file in a timely manner.