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.